U.S. Nuclear Weapon “Pit” Production Options for Congress
Released: 2014-02-21T00:00:00

Summary:
A "pit" is the plutonium core of a nuclear weapon. Until 1989, the Rocky Flats Plant (CO) mass-produced pits. Since then, the United States has made at most 11 pits per year (ppy). U.S. policy is to maintain existing nuclear weapons. To do this, the Department of Defense states that it needs the Department of Energy (DOE), which maintains U.S. nuclear weapons, to produce 50-80 ppy by 2030. While some argue that few if any new pits are needed, at least for decades, this report focuses on options to reach 80 ppy.
Pit production involves precisely forming plutonium—a hazardous, radioactive, physically quirky metal. Production requires supporting tasks, such as analytical chemistry (AC), which monitors the chemical composition of plutonium in each pit.
With Rocky Flats closed, DOE established a small-scale pit manufacturing capability at PF-4, a building at Los Alamos National Laboratory (LANL). DOE also proposed higher-capacity facilities; none came to fruition. In 2005, Congress rejected the Modern Pit Facility, viewing as excessive the capacity range DOE studied, 125-450 ppy. In 2012, the Administration "deferred" construction of the Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF) on grounds of availability of interim alternatives and affordability.
Nonetheless, options remain:
Build CMRR-NF. Congress mandated it in the FY2013 cycle, but provided no funds for it then, and permitted consideration of an alternative in the FY2014 cycle. Remove from PF-4 tasks not requiring high MAR and security. Casting pits uses much plutonium that an accident might release ("Material At Risk," MAR) and requires high security. Making 80 ppy would require freeing more MAR and floor space in PF-4 for casting. Provide regulatory relief so RLUOB could hold 1,000 grams of plutonium with few changes to the building. AC for 80 ppy needs much floor space but not high MAR or high security. Several options involve LANL's Radiological Laboratory/Utility/Office Building (RLUOB). Regulations permit it to hold 26 grams of weapons-grade plutonium, the volume of two nickels; AC for 80 ppy would require 500 to 1,000 grams and perhaps space elsewhere. Augmenting RLUOB to hold the latter amounts within regulations would be costly even though the radiation dose if the building collapsed would be very low. Regulatory relief would save time and money, but would raise concerns about compliance with regulations. A complementary option is to perform some AC at Lawrence Livermore National Laboratory or Savannah River Site. Move plutonium-238 work to Idaho National Laboratory or Savannah River Site. Fabricating plutonium-238 into power sources for space probes entails high MAR, but not high security because it is not used in pits. Moving it would free MAR and floor space in PF-4. At issue is whether to conduct all plutonium work at LANL, the plutonium "center of excellence." Build concrete "modules" connected to PF-4. This would enable high-MAR work to move out of PF-4, so PF-4 and modules could do the needed pit work. At issue: are modules needed, at what cost, and when.
Several options have the potential to produce 80 ppy and permit other plutonium activities at relatively modest cost, in a relatively short time, with no new buildings, and with minimal environmental impact. Determining their desirability and feasibility would require detailed study.
Observations include:
Differing time horizons between Congress and DOE, and between political and technical imperatives, cause problems. Doing nothing entails costs and risks. Keeping a 1950s-era building open while options are explored exposes workers to a relatively high risk of death in an earthquake. Congress may wish to consider limiting a building's permitted plutonium quantity by estimated dose instead of MAR. A facility can be safe even if it is not compliant with regulations. The political system is more flexible than the regulatory system. Regulations derive their authority from statutes. Regulators, bound by these statutes, cannot make cost-benefit tradeoffs regarding compliance. In contrast, the political system has the authority, ability, and culture to decide which tradeoffs are worth making.

subsections: section_title: Introduction
paragraphs: Of all the problems facing the nuclear weapons program and nuclear weapons complex over the past several decades, few, if any, have been as vexing as pit production. A "pit" is a hollow plutonium shell that is imploded, creating an explosion that triggers the rest of the weapon. The Rocky Flats Plant (CO) manufactured pits on a large scale during the Cold War until production halted in 1989. It took until FY2007 for the United States to produce even a small quantity, 11 pits per year (ppy), for the stockpile. Yet the Department of Defense (DOD) calls for a capacity to produce 30 ppy by 2021 as an interim goal and 50 to 80 ppy by around 2030. At issue is how to reach the higher capacity.
This report is intended primarily for Members and staff with a direct interest in pit issues, including Members who will be making decisions on pit projects that could total several billion dollars. Since the issues are complicated, this report contains technical and regulatory details that are needed to understand the advantages, drawbacks, and uncertainties of various options. It may also be of value for Members and staff with an interest in nuclear weapons, stockpile stewardship, and nuclear policy more broadly. This report begins with a description of plutonium, pits, and pit factory problems. It next considers several pit production options. It notes studies that could provide information to assist Congress in choosing among options, and concludes with several observations. There are several Appendixes, including a list of abbreviations.
The pit issue is important because of the relationship between pit production infrastructure and national goals, as shown in Figure 1 . National goals include minimizing the risk of nuclear war and, for the longer term, "the peace and security of a world without nuclear weapons," as President Obama declared in his 2009 Prague speech. The Nuclear Posture Review sets out policy objectives, such as "preventing nuclear proliferation," "reducing the role of U.S. nuclear weapons in U.S. national security strategy," "maintaining strategic deterrence and stability at reduced nuclear force levels," "strengthening regional deterrence," and "sustaining a safe, secure, and effective nuclear arsenal." Various strategies, such as deterrence, counterproliferation, and arms control, seek to implement policy. In turn, delivery systems, such as heavy bombers and long-range ballistic missiles, are one means of implementing strategy. Nuclear weapons (a term used in this report to refer to nuclear bombs and warheads) arm delivery systems. The Nuclear Posture Review declares, "The United States will not develop new nuclear warheads." Accordingly, the United States will retain the weapons in its arsenal for the foreseeable future. Yet weapons deteriorate over time. Extending the service life of existing weapons requires replacing or modifying some components. While "life extension programs" (LEPs) for some weapons can use existing pits, DOD and the Department of Energy (DOE) state that LEPs for other weapons will require newly manufactured pits. The current infrastructure cannot produce pits at the capacity DOD requires, and many efforts stretching back to the late 1980s to produce pits have been canceled or have otherwise foundered. A concern is that if a type of nuclear weapon could no longer perform satisfactorily, an inability to make new pits in the quantities required so the weapons could be replaced could lead to that weapon type being removed from service. That, in turn, would leave missiles and bombers without those weapons, which would undermine strategies, the policies they seek to implement, and the ability to attain national goals.
section_title: Background
paragraphs: This section begins by discussing plutonium, pits, pit production, programs to extend the service life of nuclear weapons, and production capacity required. It next turns to current plutonium facilities and provides a brief history of unsuccessful efforts to build a facility to produce pits on a scale larger than about 10 per year. It concludes by presenting important regulatory terms.
subsections: section_title: Technical Aspects
subsections: section_title: Plutonium
paragraphs: Plutonium is a radioactive metal that is 1.75 times more dense than lead. It has several undesirable characteristics, and is difficult to work with. According to Siegfried Hecker, a plutonium metallurgist and a former director of Los Alamos National Laboratory (LANL), 
Plutonium is an element at odds with itself—with little provocation, it can change its density by as much as 25 percent; it can be as brittle as glass or as malleable as aluminum; it expands when it solidifies; and its freshly-machined silvery surface will tarnish in minutes, producing nearly every color in the rainbow. To make matters even more complex, plutonium ages from the outside in and from the inside out. It reacts vigorously with its environment—particularly with oxygen, hydrogen, and water—thereby, degrading its properties from the surface to the interior over time. In addition, plutonium's continuous radioactive decay causes self-irradiation damage that can fundamentally change its properties over time.
To make plutonium more stable, it is typically alloyed with other materials, such as gallium.
Handling and safeguarding plutonium poses significant risks. Plutonium is hazardous: if minute particles are inhaled and lodge in the lungs, their radiation (in the form of alpha particles) can cause lung cancer. In addition, terrorists might be able to build an improvised nuclear device if they were to obtain enough plutonium, so facilities holding more than a small quantity of certain plutonium isotopes require extremely high security.
Plutonium does not occur in nature except in trace amounts. It is manufactured by exposing uranium fuel rods to neutrons in nuclear reactors, and then using chemical processes to separate it from other elements in the fuel rods. The result is a mix of plutonium isotopes. The isotope desired for nuclear weapons is plutonium-239, which fissions readily when struck by slow or fast neutrons. Weapons-grade plutonium (WGPu) consists mainly of plutonium-239 and a small fraction of other plutonium isotopes. (Note: When an isotope of plutonium is mentioned, such as plutonium-239, it is abbreviated using its chemical symbol, e.g., Pu-239.)
section_title: Pits
paragraphs: A pit is the trigger for detonating a thermonuclear weapon, or hydrogen bomb. It is a hollow shell of plutonium and other materials surrounded by chemical explosives. When the explosives detonate, they create an inward-moving pressure wave (an implosion wave) that compresses the plutonium enough to make it supercritical. It undergoes a runaway fission chain reaction, that is, an explosion. Various means are used to augment the explosion. This part of the weapon is called the primary stage. The weapon is designed so that energy from the primary stage explosion implodes the weapon's secondary stage, in which nuclear fission and fusion release most of the weapon's total explosive force.
While some pits in older weapons were made of uranium and plutonium ("composite pits"), modern pits use only plutonium because much less of that material is required to generate a given explosive force, permitting nuclear weapons to be smaller and lighter. Reducing the size and weight of weapons was important during the Cold War to maximize the number of weapons that could be fitted on a missile and to maximize the explosive force of a weapon of given weight. All nuclear weapons in the current U.S. nuclear stockpile were designed and tested during the Cold War; all but a handful were built during that time.
Because plutonium decays radioactively, there was concern that pits could deteriorate in ways that would cause them to fail. However, several studies have projected increased pit life. In 2003, pit life was thought to be 45-60 years; a 2007 study placed life for most pits at over 100 years; and a 2012 Livermore study placed the figure at 150 years. A 2013 Los Alamos study raised uncertainties on the latter claim:
Since 2006, plutonium aging work has continued at a low level. That research does not indicate any [e]ffects that would preclude the possibility of pit reuse. However, additional studies that had been planned were never undertaken, leaving some aging questions unanswered for the range of plutonium alloys in the stockpile, and for the potential applications of pit reuse now under consideration.
Penrose Albright, then Director of Lawrence Livermore National Laboratory, testified in 2013,
And there has been a pretty concerted effort at both Los Alamos and at Livermore over the last decade or more that has been looking at plutonium aging, and we actually have samples that we keep in our laboratory—and Los Alamos does the same—that are 40, 50, 60 years old that so far show no—that support the conclusions that the last decade of study has implied, which is that these pits are good for many, many more decades to come.
Longer pit life means that a stockpile of given size can be maintained with a lower pit production rate and opens the possibility of reusing retired pits.
section_title: The Pit Production Process
paragraphs: Pits must be made to exacting standards in order to function as designed. This requires precision in fabricating them and in supporting tasks.
As plutonium decays, it produces other elements, such as americium. That radioactive element increases the radiation dose to workers and is an impurity to weapons-grade plutonium. Plutonium scrap, such as from old pits or from faulty castings, may pick up other impurities. Accordingly, plutonium must be purified for use in new pits. This may involve nitric acid processing, high-temperature processing, electrorefining, and other processes. Such processes result in a substantial stream of waste contaminated with radioactive material, acid, and other harmful substances. This waste must be processed and disposed of; waste processing requires a substantial infrastructure.
Pits are fabricated as "hemishells" (half-pits) that are welded together. Rocky Flats Plant made pits using a wrought process, in which sheets of plutonium were run through rollers to attain the desired thickness, then punched into a die. LANL, where pits are currently made, uses a cast process, in which plutonium is melted in crucibles in a foundry, poured into a mold, and finished. The plutonium is analyzed chemically, and each hemishell is inspected through such techniques as physical measurements and x-ray imaging to ensure that there are no flaws. Given the many steps required, it typically takes three months to make a pit.
Various tasks support production. Materials characterization (MC) examines bulk properties of plutonium samples, such as tensile strength, magnetic susceptibility, and surface characteristics. Such properties must be determined to be correct to assure that a pit will, for example, implode symmetrically. MC is generally used to qualify manufacturing processes and to troubleshoot production problems. As such, it does not generate a large number of samples during production, and that number is largely independent of the number of pits to be produced. Of relevance to options considered below, MC does not require a large amount of laboratory floor space.
In contrast, analytical chemistry (AC) is performed across the entire manufacturing process, from metal purification through waste processing. Samples are analyzed for isotopic composition of plutonium and for the type and amount of various impurities. AC is performed on an average of 22 samples per pit. Metal samples taken directly from hemishells are typically 5 grams each. In preparing for AC, these samples are cut into smaller pieces. Most of the smaller pieces are dissolved in acid because most AC instruments do not use samples in solid form. The resulting plutonium-acid mixture is split into still smaller samples, many of which contain milligram or microgram quantities of plutonium. Each sample must be prepared in a specific way, and analyzed using specific equipment, depending on the type of analysis that it is to undergo. In addition, before plutonium ingots are used for a hemishell, their purity must be assayed. This involves taking a sample from a piece of the purified product as well as plutonium standard and reference materials for comparison. In order to provide one assay result for the plutonium, the assay process is typically run 10 times.
Pit fabrication generates waste, such as the plutonium-acid samples used in AC, the MC samples, and any shavings or trimmings from finishing hemishells. Accordingly, pit production requires a way to handle the waste. It is treated two ways at Los Alamos; in some cases by extracting plutonium, and in other cases by solidifying it for burial at the Waste Isolation Pilot Plant (WIPP) (NM).
section_title: Life Extension Programs
paragraphs: While pits may last for many decades, other weapon components do not. Weapons contain organic components like explosives and adhesives that deteriorate under the influence of heat and radiation given off by plutonium; they may change characteristics over time. Some components, such as electronics, become hard to support after several decades, would be even harder to support several decades from now, and would be difficult to make compatible with new delivery systems like aircraft. Beyond that, some in the National Nuclear Security Administration (NNSA) and DOD want to increase the surety (safety, security, use control, and use denial) of weapons. (NNSA is the semiautonomous DOE agency responsible for nuclear weapons maintenance, several nuclear nonproliferation programs, and all naval nuclear propulsion work.) Accordingly, the Nuclear Weapons Council, a joint DOD-NNSA body that oversees and coordinates nuclear weapon programs, plans a life extension program (LEP) for each weapon type, including some LEPs that may combine two or more weapon types. LEPs range in scope from replacing a few components to a major overhaul that includes new pits, new electronics, and new surety features. Some dispute the need for LEPs that do more than the minimum needed to keep a weapon in service. They argue, for example, that features to further enhance surety are unnecessary given the perfect safety record of U.S. nuclear weapons and that these features add greatly to cost and may impair weapon performance. Nonetheless, LEPs are underway for the W76 warhead for the Trident II submarine-launched ballistic missile and the B61 bomb, and both Congress and the Administration support them. Additional LEPs are being planned.
section_title: Pit Production Capacity: How Much Is Needed?
paragraphs: Some LEPs can use the original pit and replace other components, while other LEPs might reuse pits from retired weapons if that proves feasible, and still other LEPs are expected to require fabrication of new pits. U.S. policy, as stated in the Nuclear Posture Review, is specific on its preference among these choices:
The United States will study options for ensuring the safety, security, and reliability of nuclear warheads on a case-by-case basis, consistent with the congressionally mandated Stockpile Management Program. The full range of LEP approaches will be considered: refurbishment of existing warheads, reuse of nuclear components from different warheads, and replacement of nuclear components.
In any decision to proceed to engineering development for warhead LEPs, the United States will give strong preference to options for refurbishment or reuse. Replacement of nuclear components would be undertaken only if critical Stockpile Management Program goals could not otherwise be met, and if specifically authorized by the President and approved by Congress.
The need for new "nuclear components," pits in this case, drives pit capacity requirements. However, the pit production capacity considered has varied greatly, from 10 to 450 pits per year. The Nuclear Weapons Council has decided that, to meet the likely demands of future LEPs, a production capacity of 50 to 80 ppy is needed. Andrew Weber, Assistant Secretary of Defense for Nuclear, Chemical, and Biological Defense Programs, testified in April 2013 that "there is no daylight between the Department of Energy and the Department of Defense on the need for both a near-term pit production capacity of 10 to 20 and then 30 by 2021, and then in the longer term for a pit production capacity of 50 to 80 per year."
While this range of pit production drives the planning for the U.S. plutonium strategy, it is not a precise range based on a careful analysis of military requirements. When asked to explain the basis for this range, Linton Brooks, former Administrator of NNSA, and John Harvey, then Principal Deputy Assistant Secretary of Defense for Nuclear, Chemical, and Biological Defense Programs, responded: 
MR. HARVEY: We established that requirement back in 2008 for a capability to produce in the range of 50 to 80 per year. That evolved from a decision to basically not take the path that we originally were taking with the Modern Pit Facility, but to go and be able to exploit the existing infrastructure at Los Alamos to meet our pit operational requirements. The capability at Los Alamos was assessed to be somewhere in the range of 50 to 80 per year that they could get with the modernization program they anticipated. The Nuclear Weapons Council looked at that number. It's a capacity-based number, and said it's probably good enough. We'll have to accept some risk, but it's probably good enough.
MR. BROOKS: So you can't tie it to a specific – you can't tie it to a specific deployment schedule or something. It's a judgment that is a combined judgment on yeah, you can probably do this, and yeah in the most reasonable world this will be enough.
MR. MEDALIA: But there's a big difference in the facilities, between 50 and 80. Is it 80 or is it 50 to 80?
MR. HARVEY: We understood that the capability to deliver, based on the anticipated modernization at Los Alamos which would include the CMRR or equivalent, coupled with the PF-4 production, appropriately reconfigured, could deliver in that range. So it was a range. I mean, it's always been cited as single shift range. By going to double shifts you could probably get the higher end of that range.
MR. BROOKS: But no person now living can tell you for sure the answer to that question. I mean, you know, beware of spurious precision. … Fifty to 80 is probably as precise as the facts will allow people to be, although people will say other things.
NNSA was also imprecise as to required production capacity. It stated in a 2013 report, "Preliminary plans call for pit production of potentially up to 80 pits per year starting as early as FY 2030. NNSA continues to develop options to achieve a higher production rate as part of the plutonium strategy." John Harvey subsequently added, "The level of 50-80 ppy was consistent with existing PF-4 production capacity plus the analytical chemistry capacity anticipated for the planned CMRR-NF. However, NNSA officials in 2006 believed that a capacity in the range of 125 ppy was needed to respond to anticipated requirements and provide some resilience to surprise. Thus the 50-80 ppy level, while the best that could be done, accepted significant risk in their view."
It may be possible to reduce the capacity required below 80 ppy and still meet DOD's requirements. This might be done in several ways:
One option under serious study is reusing retired pits in LEPs. Whether this could be done for a particular LEP depends on details of the LEP, whether there are suitable pits available, and whether such pits are available in the quantity required; decisions would have to be made on a case-by-case basis. In some LEPs, it may be possible to simply reinstall a weapon's original pit. Neither that method nor reuse of retired pits from other weapons require AC or foundry work. By producing new pits while another LEP is underway with retired or original pits, LANL could use its otherwise-unused capacity to produce pits ahead of schedule for a LEP requiring new pits. Stockpiling new pits would enable lower rates of production and of AC to produce the aggregate number of pits needed by the time they are needed, even if the maximum production rate attainable is less than 80 ppy. In addition, keeping the pit production and support line in continuous operation would be useful if not essential for maintaining processes, equipment, and worker skills, and for training new workers. On the other hand, LEPs require considerable planning and design work, and designs for new pits would have to be certified. In the near term, it might not be possible to do this work far enough in advance to permit continuous production. Since the figure of 80 ppy was based on LANL's presumed pit production capacity using PF-4 and CMRR-NF (an existing building and one that has been deferred for at least five years), not on a strategic analysis of military needs, and since the range cited is 50 to 80 ppy, a capacity of less than 80 ppy might suffice.
The Union of Concerned Scientists stated regarding required pit production capacity:
If pits last 150 years or more, there is no need to replace aging pits for the foreseeable future, and no rationale for expanding production capacity beyond the existing 10 to 20 annually for this purpose. Even if the NNSA finds that pits will last only 100 years and that all need to be replaced by 2089, production capacity of 50 per year would be adequate.
The NNSA could replace all existing pits by 2089 if it started doing so in 2019, based on the agency's conservative assumption that the U.S. stockpile will remain at 3,500 warheads. However, the United States is likely to reduce its arsenal in coming decades. In that case, the NNSA could either wait longer to begin producing replacement pits … or reduce the annual rate of production. …
Thus, even under the most conservative assumptions about pit lifetime and arsenal size, there is no need to expand pit production capacity beyond 50 per year to replace aging pits. Because both pit lifetime and the future size of the arsenal are uncertain, it makes no sense to expand production capacity until it is needed.
In contrast, John Harvey argues that there is risk in not providing margin to accommodate unknowns:
Required pit production capacity cannot be based solely on known LEP requirements. We must consider the possibly of surprise: either technical problems in the stockpile that arise unexpectedly or geopolitical reversals. For example, we cannot anticipate at this point a need to increase stockpile size based on renewed threats, but we should not rule out that possibility in setting our pit production needs. Some reserve production capacity is required above and beyond known LEP needs to ensure we have some ability to respond to surprise.
This is entirely consistent with the President's NPR [Nuclear Posture Review] vision for a responsive nuclear infrastructure. The longer we wait on achieving needed capacity, the greater the risk we are accepting in not having responsive capabilities.
It could be argued that an ability to meet the higher requirement—the most challenging case—would enable the United States to meet lower requirements and would put this nation in a better position to meet higher requirements should that be deemed necessary. Further, if 80 ppy proves unattainable, an effort to reach that goal might increase the likelihood that this nation could reach 50 ppy, the lower end of the range.
On the other hand, it could be argued that it is not desirable to have a goal of 80 ppy if that is excess to needs. According to Greg Mello, Executive Director of Los Alamos Study Group,
It is not clear that efforts to reach a larger pit production capacity will enable lesser pit production capacities. History shows that efforts to acquire pit production capacity above that which is clearly needed, have failed. Facilities to support a larger-than-needed pit production capacity cost more for construction and operation than smaller facilities, and are more likely to encounter political objections. So trying for 80 pits per year may decrease the probability of successfully acquiring 50 pits per year, and trying for 50 pits per year may decrease the probability of achieving 30 pits per year. It may be far better to acquire the minimum necessary pit production capacity, and include a contingency plan that can be activated should conditions warrant.
Because of concern over required pit production capacity, Section 3147 of the FY2013 National Defense Authorization Act, P.L. 112-239 , directed the Secretary of Defense, in coordination with the Secretary of Energy and the Commander of the U.S. Strategic Command, to "assess the annual plutonium pit production requirement needed to sustain a safe, secure, and reliable nuclear weapon arsenal." The accompanying Joint Explanatory Statement of the Committee of Conference states that the assessment shall include "an assessment of cost and national security implications for various smaller and larger pit production rates from the current 50-80 pit requirement. The conferees note that rates including 10 to 20 pits per year, 20 to 30 pits per year, 30 to 50 pits per year, 50 to 80 pits per year, and larger should be included as part of the analysis." Note that reducing required capacity would reduce facility requirements and might permit delaying facility construction.
The purpose of this report, however, is not to address contending arguments on the capacity needed, but to discuss options for acquiring the maximum capacity DOD states that it needs, 80 ppy, by 2030. Even if in 16 years it turns out that a lower capacity would suffice, it is difficult at best to know that so far in advance.
The difference between 50 and 80 ppy has consequences. As discussed above, the Nuclear Weapons Council reasoned that a capacity to build 50 ppy in single-shift operations could be scaled up to produce 80 ppy in double-shift operations, that is, double-shift operations can produce 1.6 times as many pits as single-shift operations. But if the actual need is 50 ppy, then by using the same ratio, a capacity to build approximately 30 ppy in single-shift operations could be scaled up to 50 ppy by using two shifts. Deploying and operating a smaller capacity would be less costly and easier to implement.
section_title: Plutonium-238
paragraphs: Pu-238 is an isotope of plutonium. While it is not used in pits, it figures prominently in several pit production options presented later in this report. It has very different properties and applications than Pu-239. Pu-238 has a much shorter half-life than Pu-239 (87.7 years vs. 24,110 years), so is 275 times more radioactive. Because of its intense radioactivity, it is so hot that a lump of it glows, as Figure 2 shows. This radioactivity makes it useful in applications requiring a long-lived power source. It is used to provide heat to generate electricity for deep space probes and for defense purposes. At the same time, according to Los Alamos,
Pu-238 is not desirable for using in pits because it has a relatively short half-life (87.7 years) and the associated decay generates large amounts of heat in the material. Pu-238 is listed in the [DOE] Safeguards Table (DOE 474.2) as attractiveness level D (Low-Grade Materials) because its half-life and associated properties would make it extremely difficult to fabricate into a pit, handle, and may cause problems for surrounding materials [in a nuclear weapon] such as electronics, plastics, etc.
section_title: Key Regulatory Terms
paragraphs: Statutes, regulations, DOE orders, etc., as described in Appendix A , use many terms. While they are often technical and complicated, understanding several of them is essential for understanding facilities, presented next, and options. Selected terms are presented here; they provide a basis for discussing constraints on plutonium buildings, various ways to comply with these constraints, and how the constraints might be modified.
Dose: The amount of ionizing radiation a person receives, measured in rem.
Rem: This is a unit of measure of the biological effects of all types of ionizing radiation on people. One expert lists a dose of between 0 and 25 rem as having "no detectable clinical effects; small increase in risk of delayed cancer and genetic effects," a dose of 25 to 100 rem as "serious effects on average individual highly improbable," and for 100-200 rem "minimal symptoms; nausea and fatigue with possible vomiting." Note that cancer risks in exposed populations generally increase with dose and number of people exposed.
Plutonium-239 equivalent: Weapons-grade plutonium (WGPu) consists mainly of Pu-239 but includes small quantities of other plutonium isotopes. Some are much more radioactive than Pu-239, and there are many other radioactive substances. It is convenient to convert all radioactive materials to a single standard for purposes of assessing the radiological hazard from a building in the event of an accident. That standard is "plutonium-239 equivalent," abbreviated as Pu-239E in this report. Because WGPu is more radioactive than pure Pu-239, 1 gram (g) of WGPu has the radioactivity of 1.49 g of Pu-239. Similarly, Pu-238 is very much more radioactive than Pu-239; 1 g of Pu-238 has the radioactivity of 275 g of Pu-239.
Hazard Categories (HCs) and Radiological Facilities : Nuclear facilities are categorized in several ways. One is by the hazard they could pose in the event of a major accident. HCs are based on "the consequences of unmitigated releases of hazardous radioactive and chemical material." 10 CFR 830, "Nuclear Safety Management," Appendix A, "General Statement of Safety Basis Policy," divides these consequences into three categories; Table 1 also includes a related category.
Hazard Categories are determined by the amount of Pu-239E a building is designed to hold; each category has the potential for certain consequences in the event of a major accident. 10 CFR 830, Appendix A, states that "the hazard categorization must be based on an inventory of all radioactive materials within a nuclear facility." The HC structure builds in a conservative feature: "The final categorization is based on an 'unmitigated release' of available hazardous material. For the purposes of hazard categorization, 'unmitigated' is meant to consider material quantity, form, location, dispersibility and interaction with available energy sources, but not to consider safety features (e.g., ventilation system, fire suppression, etc.) which will prevent or mitigate a release." Hazard Categories apply to the design and construction of a building, not to its operation. For example, a building intended to hold 5,000 g of Pu-239E must be designed to HC-2 standards, while a building intended to hold 1,000 g of Pu-239E must be designed to HC-3 standards, which are less stringent. 
Closely related, and central to some options discussed later in this report, is the category "Radiological Facility." A Radiological Facility holds less Pu-239E than an HC-3 building. It is not part of the HC system because the amount of material is so small as to pose little threat; a hospital, for example, might be a Radiological Facility. The Radiological Laboratory/Utility/ Office Building (RLUOB) figures in several options below and is discussed in " Existing Buildings at Los Alamos for Plutonium Work ." As a Radiological Facility, HC standards limit it to 38.6 g of Pu-239E, or 26 g of WGPu, far less than enough to perform the AC needed to support production of 80 ppy.
Design Basis Earthquake (DBE): The DBE is used to set standards for the resilience to earthquakes that buildings in various HCs must have. LANL provided the following information: 
The design basis earthquake is defined as the ground motion that has an annual frequency of 4 x 10 -4 or [once in] 2,500 years. This is the ground motion that structures, systems, and components (SSCs) are designed for using national consensus codes and standards. This approach would lead to a failure probability of the SSCs for loads associated with the design basis ground motion of 1-2%. Using this approach it is also expected that at ground motion associated with an annual frequency of 1 x 10 -4 , or [once in] 10,000 years, the failure probability of the SSCs would be about 50%.
Design Basis Accident (DBA): This is the accident scenario against which a nuclear facility must be designed and evaluated. Each HC building is required to be built to survive a DBA, the worst-case accident that could plausibly affect the building. Because each building will face different threats, the DBA is necessarily building-specific. For one building, the DBA might be a flood; for another, an explosion of a nearby gas main; for a third, a tornado; and for a fourth, an earthquake. For the plutonium buildings at Los Alamos, described next, the main threat is an earthquake, so the DBA involves (1) an earthquake more powerful than the DBE that (2) collapses a building and (3) starts a fire that involves all material at risk in the facility and (4) releases a certain fraction of the plutonium into the air as plutonium oxide particles. The fraction, in turn, is based on (1) the Airborne Release Fraction (ARF), the fraction of the MAR that the postulated fire could release into the air; (2) the Leak Path Factor (LPF), the fraction of ARF that actually escapes from the building into the air; some of it would be trapped, such as by the collapse of the building; and (3) the Respirable Fraction (RF), the fraction of the plutonium oxide particles released into the atmosphere that are of a size (3 microns or less) that could readily be inhaled and lodge in the lungs, where they would cause biological damage and, quite possibly, lung cancers; larger particles would fall to the ground or would be trapped in the nose. Other variables enter as well; Appendix B discusses them in detail.
The frequency of the DBA is much less than the frequency of the DBE because several steps must occur for the DBE to result in the DBA. NNSA commented on this difference:
There is also margin in the assumed accident frequencies (e.g., once in 5,000 years); these were based on the structural failure probabilities and did not consider other conditional probabilities, such as the conditional probability of a large fire starting and growing within the facility and progressively effecting and engaging all of the assumed material at risk; this refinement would reduce the frequency of the event from once in thousands of years to once in hundreds of thousands of years.
The difference between DBE and DBA is crucial because the path from the one to the other can be interrupted at many places and in many ways in order to reduce the probability of the DBA, as discussed in " Increasing Safety ," below.
Radiological Facilities like RLUOB do not have a DBA and do not have to be designed to survive a DBA because they have so little radioactive material, though, as discussed in Appendix E , RLUOB was built (but not certified) to HC-3 standards. If RLUOB were to be converted to an HC-3 building, it would need a DBA and might need structural and other upgrades to be able to survive it. Appendix D describes some of the tasks needed to convert RLUOB to HC-3.
Material At Risk (MAR): DOE defines this term as "the amount of radioactive materials (in grams or curies of activity for each radionuclide) available to be acted on by a given physical stress." For purposes of this report, it is a measure of the amount of plutonium that might be dispersed in a DBA. Molten plutonium or plutonium shavings in a crucible that topples over in an earthquake, spilling plutonium onto the floor, would be MAR because a fire would create plutonium oxide particles, while plutonium in specially designed containers that are fire-resistant and rugged enough to survive a building collapse would not face this risk and thus would not be counted as MAR.
Maximally-exposed Offsite Individual (MOI) and other exposure standards: An MOI is a hypothetical person located at the spot—outside the site boundary but nearest to a specific building—where a member of the public could reasonably be, such as a dwelling or a public road. The guideline set by DOE is that the MOI should receive a dose of no more than 25 rem for an exposure of 2 hours (or up to 8 hours in certain situations). "The value of 25 rem TEDE [total effective dose equivalent] is not considered an acceptable public exposure either. It is, however, generally accepted as a value indicative of no significant health effects (i.e., low risk of latent health effects and virtually no risk of prompt health effects)." To avoid "challenging" the 25-rem dose, another DOE document sets the dose at 5 rem, and sets a guideline of 100 rem TEDE for nearby ("collocated") workers.
Documented Safety Analysis (DSA): Once an HC-2 or HC-3 building is built, a DSA must be prepared for it. A DSA is an agreement on how much MAR it can contain in order to stay within the dose limits for a collocated worker (for an HC-3 building) or an MOI (for an HC-2 building). The DSA MAR limit is typically less than the upper bound for an HC-3 building; for an HC-2 building, the DSA MAR limit is a specific figure because HC-2 sets no upper bound. For two HC-2 buildings at LANL, CMR and PF-4, discussed below, the agreement is between NNSA and Los Alamos National Security, LLC, the site contractor. The MAR permitted is building-specific based on hazard analysis, including accident scenarios, and on multiple measures designed to contain radioactive material in an accident. For CMR, the MAR permitted by the DSA is 9 kg of Pu-239E; for the main floor of PF-4, the comparable figure is 2,600 kg. A DOE document provides detailed standards for preparing a DSA. No DSA is required for a Radiological Facility because MAR is so small that such facilities fall outside the Hazard Category system.
Security Category (SC): DOE places uranium and plutonium into SCs depending on their attractiveness level, such as to terrorists. SC I and II pertain to facilities with Special Nuclear Materials (SNM, mainly uranium highly enriched in the isotope 235 and plutonium) in quantities or forms that would pose a severe threat if seized by terrorists. The highest level, SC-I, includes assembled weapons and 2 kg or more of plutonium ingots. SC I and II require armed guards, a special security fence, and similar measures. SC-IV requires much less security. It includes less than 200 g of metallic plutonium and less than 3 kg of solutions of less than 25 g of plutonium per liter. Table C-1 shows amounts of plutonium in various hazard and security categories.
Safety Class, Safety Significant: 10 CFR 830.3 defines safety class structures, systems, and components (SSCs) as SSCs, "including portions of process systems, whose preventive and mitigative function is necessary to limit radioactive hazardous material exposure to the public, as determined from the safety analyses." In contrast, safety significant SSCs "are not designated as safety class structures, systems, and components, but whose preventive or mitigative function is a major contributor to defense in depth and/or worker safety as determined from safety analyses." LANL added this explanation: "Safety-class systems must operate in conditions that otherwise would result in an unacceptable risk (dose) to the public. Relative to the public, safety-significant systems support safety-class systems with additional protections that might help in an accident, but are not counted upon to do so."
section_title: Facility Aspects: Buildings to Support Pit Production
subsections: section_title: Existing Buildings at Los Alamos for Plutonium Work
paragraphs: The nuclear weapons complex (the "Complex") consists of eight sites that maintain U.S. nuclear weapons; during the Cold War, the Complex designed, developed, tested, and manufactured these weapons. The Department of Energy (DOE) and its predecessor agencies used to own and set policy for the Complex. Beginning in 2000, the National Nuclear Security Administration (NNSA), a semiautonomous agency within DOE, took over these functions. Contractors operate Complex sites at the direction of NNSA. One of these sites, Los Alamos National Laboratory (LANL), has three buildings relevant to pits:
subsections: section_title: Chemistry and Metallurgy Research (CMR) Building
paragraphs: This building was designed beginning in the late 1940s; most of it was completed by 1952, with another part completed in the early 1960s. It was used mainly for plutonium R&D, and at present provides AC and some MC to support pit production and all other plutonium missions in PF-4.
CMR is showing signs of age. In 2009, a congressional commission found that it and a uranium processing building at the Y-12 National Security Complex are "genuinely decrepit and are maintained in a safe and secure manner only at high cost." In 2010, the staff of the Defense Nuclear Facilities Safety Board (DNFSB), which monitors safety and health issues at the nuclear weapons complex, "questioned CMR's ability to detect promptly ventilation system failure, a particularly important function given the system's age and lack of local alarms to notify facility workers." In a 2010 report to Congress, DNFSB stated that CMR and Y-12 uranium processing facilities "are structurally unsound and are unsuitable for protracted use."
CMR suffers from another problem. As Los Alamos is on several seismic faults, earthquakes pose the greatest threat to CMR. It is not seismically robust. Its design, in the late 1940s, gave little consideration to seismic loads. Further, when it was constructed, there was a steel shortage due to a steel strike and the Korean War. To save on steel, each concrete beam in CMR is reinforced with only two steel reinforcing rods, which are of different diameters, while the concrete floor between the beams is 2 to 4 inches thick, reinforced with chicken wire. A Los Alamos seismic expert calculates that, for CMR, "the annual probability of failure [i.e., building collapse, is] somewhere between 1 in 370 years and 1 in 333 years." This means that for ground motion that might be associated with an earthquake that may occur approximately every 250 years, there is a 50% probability of collapse. This expert also calculates that the probability that CMR would survive a Design Basis Earthquake, in this case one occurring once in 2,500 years, is less than 0.2%. Another calculation using these data is that CMR has a 1 in 36 chance of collapsing in 10 years. DNFSB arrived at a similar calculation:
Seismic fragility of building: There is a 1 in 55 chance of seismic collapse during a 10-year timeframe, which would result in release of nuclear material and injury/death of facility workers.
The Board is concerned that prolonged operations in the existing CMR facility pose a serious safety risk to workers. In late 2010, the NNSA limited material-at-risk in the facility to reduce the public dose consequence following an earthquake to a value below the Evaluation Guideline of 25 rem.
section_title: PF-4 (Plutonium Facility 4)
paragraphs: PF-4 is the nation's main building for plutonium work. It manufactures pits and supports many other plutonium projects. It produces Pu-238 heat sources for deep space probes and defense purposes. It houses the Advanced Recovery and Integrated Extraction System (ARIES), which converts the plutonium in pits into plutonium oxide for use in mixed oxide nuclear reactor fuel. It is the venue for pit surveillance, in which pits from deployed weapons are returned to Los Alamos for detailed inspection to search for actual or potential problems. It used to recover americium, a decay product of plutonium, for use in smoke detectors and industrial gauges, and is reestablishing that capability. It conducts plutonium R&D.
DNFSB expressed concern about PF-4's vulnerability to an earthquake: 
PF-4 was designed and constructed in the 1970s and lacks the structural ductility and redundancy required by today's building codes and standards. In 2007, a DOE-required periodic reanalysis of the seismic threat present at the Los Alamos site was completed. It indicated a greater than fourfold increase in the predicted earthquake ground motion. Total facility collapse is now considered a credible event. … In response to this increased seismic threat, LANL undertook a series of actions to improve the safety posture of PF-4.
section_title: Radiological Laboratory/ Utility/Office Building (RLUOB)
paragraphs: Design of this building was completed in 2006. The building was completed in FY2010, office operations began in October 2011, and laboratory operations are expected to start in 2014. As a Radiological Facility, it is permitted to hold 26 grams (g) of WGPu. It has 19,500 square feet (sf) of laboratory space, as compared to 22,500 sf of lab space planned for the Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF), a building planned but not built, as described in " A Sisyphean History: Failed Efforts to Construct a Building to Restore Pit Production ," below. RLUOB (pronounced "rulob") was intended to conduct unclassified R&D on plutonium and some AC in support of pit production; the latter amount was to be very small because CMRR-NF was intended for that purpose. Nonetheless, the design of RLUOB is suitable for AC because it uses open hoods instead of gloveboxes as in PF-4; hoods are more efficient for most AC because it is much easier to work with small samples in them, but they require a powerful ventilation system, which RLUOB has, as shown in Figure 6 . Indeed, a LANL report stated that "RLUOB has effectively perfect alignment with analytical chemistry activities."
While RLUOB was intended to be a Radiological Facility, it was constructed to a much higher standard than was required: 
RLUOB was built as a "radiological-plus" or robust radiological facility. The engineering controls associated with worker radiation protection are on par with those inside of PF-4 and well in excess of those in the 1950s-era CMR Building. Additionally, the RLUOB uses modern HEPA filtration, which protects the environment from a release of contamination, and contains a state-of-the-art operations center for managing facility operations including ventilation. In an overarching sense, the RLUOB was built with a focus on the Nuclear Quality Assurance (NQA)-1 standard, which technically is only required for hazard category 3 facilities, but was constructed as such to provide lessons-learned to aid in constructing the CMRR-NF. However, despite its inherent robustness, the RLUOB does not meet the standards established for either a hazard category 2 or 3 nuclear facility because it was by design intended to work in conjunction with a hazard category 2 nuclear facility (the CMRR-NF).
RLUOB was designed to withstand the design basis earthquake (DBE), in this case an earthquake anticipated to strike RLUOB once in 2,500 years. The force of the DBE was based on seismic calculations made in 1995. Accordingly, it is more resilient to earthquakes than PF-4 was as originally built, since PF-4 was designed to an earlier, less energetic DBE. (Upgrades have increased PF-4's resiliency.) As detailed in Appendix E , Los Alamos estimates that "collapsing RLUOB would take an earthquake with 4 to 12 times more force than an earthquake that would collapse CMR." However, the current DBE is more energetic than the 1995 DBE; it is unclear what measures, if any, would be needed to strengthen RLUOB to withstand the current DBE.
section_title: A Sisyphean History: Failed Efforts to Construct a Building to Restore Pit Production
paragraphs: Beginning in 1952, the United States made pits on a large scale at the Rocky Flats Plant (CO), sometimes over 1,000 ppy. Operations there halted in 1989 as a result of an FBI raid investigating safety and environmental violations. At that point, Rocky Flats was producing pits for the W88 warhead to be carried by Trident II submarine-launched ballistic missiles, but W88 production was not complete. DOE initially considered restarting operations at Rocky Flats, but ultimately decided not to. The United States has not had the capacity to make more than about 10 ppy since 1989.
The history of efforts to restore pit production capacity on a larger scale is voluminous. The key takeaways from the brief summary that follows are: (1) many projects have been proposed over the years; (2) none has been successfully completed; and (3) key parameters, such as cost, schedule, proposed facility site, and capacity, have changed from one proposal to the next.
subsections: section_title: Complex 21
paragraphs: As the Cold War was winding down, Congress, in Section 3132 of the National Defense Authorization Act for FY1988 and 1989 ( P.L. 100-180 , December 4, 1987), directed the President to conduct a study on nuclear weapons complex modernization and to "formulate a plan … to modernize the nuclear weapons complex by achieving the necessary size and capacity determined under the study." The report was submitted in January 1989, but as Secretary of Energy James Watkins noted in January 1991, 
dramatic world changes forced further reassessments of the future Nuclear Weapons Complex." A DOE report resulting from the reassessments "presents a plan to achieve a reconfigured complex, called Complex-21. Complex-21 would be smaller, less diverse, and less expensive to operate than the Complex of today. Complex-21 would be able to safely and reliably support nuclear deterrent stockpile objectives set forth by the President and funded by the Congress.
In addition to a No Action alternative, the study proposed two Reconfiguration alternatives. One would downsize existing sites and modernize them in place. "As an exception to the existing site theme, the functions of the Rocky Flats Plant (RFP) would be relocated." The second, "maximum consolidation," would
relocate RFP and at least one other NMP&M [Nuclear Materials Production and Manufacturing] facility to a common location. The Pantex Plant and the Oak Ridge Y-12 Plant are candidates for collocation with the Rocky Flats functions, either singly or together. … The probable outcome of this option would be an integrated site which could consolidate much of the NMP&M elements at a single site.
As part of this effort, DOE would develop a Programmatic Environmental Impact Statement "to analyze the consequences of alternative configurations for the Complex," with completion of that statement expected in early FY1994. "Complex-21 should be fully operational early in the 21 st century and will sustain the nation's nuclear deterrent until the middle of that century."
What emerged was a two-pronged approach to restore pit production. After conducting an environmental impact statement (EIS) process, DOE issued a Record of Decision (ROD) on Stockpile Stewardship and Management in December 1996 that included reestablishing pit production capability at PF-4 while raising the prospect of a larger-capacity facility. Los Alamos would build a small number of pits for W88s so DOE could replace W88 pits destroyed in an ongoing surveillance program that monitored their condition. Producing these pits, and certifying them as "war reserve," that is, meeting standards for use in the nuclear stockpile, took many years; PF-4 produced its first war reserve W88 pits, 11 of them, in 2007. This small capacity would also serve as a pilot plant for developing production techniques for a larger plant. Since the total number of additional W88 pits required was small, about 30, there was no need for PF-4 to achieve high manufacturing rates. Producing these pits and certifying them as war reserve without nuclear testing was a major early challenge for the stockpile stewardship program.
section_title: Modern Pit Facility
paragraphs: The second prong was to build a facility able to produce large numbers of pits. This was the Modern Pit Facility (MPF). NNSA approved Critical Decision 0 (mission need) for MPF in FY2002. The capacity of MPF was left to be decided, for reasons a National Environmental Policy Act (NEPA) document of May 2003 noted:
Classified studies have examined capacity requirements that would result from a wide range of enduring stockpile sizes and compositions, pit lifetimes, emergency production needs (referred to as "contingency" requirements), and facility full-production start dates. Although the precise future capacity requirements are not known with certainty, enough clarity has been obtained through these ongoing classified studies that the NNSA has identified a range of pit production capacity requirements (125-450 ppy) that form the basis of the capacity evaluations in this EIS. The EIS evaluates the impacts of a MPF designed to produce three capacities: 125 ppy, 250 ppy, and 450 ppy. A pit lifetime range of 45-60 years is assumed.
Congress initially supported MPF, but became increasingly concerned with the lack of study of alternatives, a lack of clarity on the production capacity required, and uncertainty on pit aging and pit life. Finally, Congress eliminated funds for MPF in the FY2006 budget cycle.
section_title: Consolidated Nuclear Production Center
paragraphs: Another effort to reconfigure the nuclear weapons complex began in 2004, when the House Appropriations Committee sought to have DOE link the nuclear weapons stockpile with the nuclear weapons complex that would support it:
During the fiscal year 2005 budget hearings, the Committee pressed the Secretary on the need for a systematic review of requirements for the weapons complex over the next twenty-five years, and the Secretary committed to conducting such a review. The Secretary's report should assess the implications of the President's decisions on the size and composition of the stockpile, the cost and operational impacts of the new Design Basis Threat, and the personnel, facilities, and budgetary resources required to support the smaller stockpile. The report should evaluate opportunities for the consolidation of special nuclear materials, facilities, and operations across the complex to minimize security requirements and the environmental impact of continuing operations.
The Secretary of Energy Advisory Board (SEAB) formed the Nuclear Weapons Complex Infrastructure Task Force to carry out this study. The task force issued its report in July 2005. It recommended immediate design of a Reliable Replacement Warhead (RRW). RRW was a concept in which Cold War aspects of nuclear weapon design, notably maximizing the explosive yield of the weapon per unit weight (the "yield-to-weight ratio"), would be traded off for design features more suitable to the post-Cold War world, such as ease of manufacture, enhanced confidence without nuclear testing, reduced use of hazardous materials, and enhanced surety features. The task force envisioned RRW as a "family of weapons," with RRWs ultimately making up most if not all of the future stockpile. The task force also recommended a Consolidated Nuclear Production Center (CNPC), "a modern set of production facilities with 21 st century cutting-edge nuclear component production, manufacturing, and assembly technologies, all at one location … When operational, the CNPC will produce and dismantle all RRW weapons." CNPC would have an SNM manufacturing facility, part of which would support plutonium operations. "All of the functions currently identified in the proposed Modern Pit Facility (MPF) will be located in this building" except for plutonium R&D. CNPC would not manufacture non-nuclear components. Regarding capacity, the report stated:
A classified Supplement analyzes the issue of timing for the CNPC for a stockpile of 2200 active and 1000 reserve [weapons] and the expected pit manufacturing capacity of the future Complex. The conclusion is that if the NNSA is required to: 1) protect a pit lifetime of 45 years, 2) support the above stockpile numbers, and 3) demonstrate production rates of 125 production pits to the stockpile per year, the CNPC must be functional by 2014. If one accepts the uncertainty of pit lifetime of 60 years, the CNPC can be delayed to 2034. In either case TA-55 is assumed to be producing 50 production pits to the stockpile per year.
section_title: Complex 2030
paragraphs: The FY2007 National Defense Authorization Act, P.L. 109-364 , directed the Secretary of Energy to develop a plan for transforming the nuclear weapons complex to provide a responsive infrastructure by 2030, and to submit this plan to Congress. The report was submitted in October 2006. The goal was to implement U.S. policy on strategic deterrence as called for in the 2001 Nuclear Posture Review, which recognized the need to transform U.S. nuclear forces from deterring the U.S.S.R. to responding to emerging threats. Regarding the stockpile, NNSA envisioned a smaller stockpile that, by 2030, would be composed mainly if not entirely of RRWs. While the nuclear weapons complex of 2030, "Complex 2030," would continue to have eight sites, quantities of SNM requiring high levels of security would be "only present at production and testing sites." As to labs, in Complex 2030 "No laboratory operations require Category I/II SNM levels of security. Laboratory facilities are not used for nuclear production missions." Unlike the SEAB report, Complex 2030 would not have a Consolidated Nuclear Production Complex but would have "full operations of a consolidated plutonium center at an existing Category I/II SNM site in the early 2020s." Further, "By 2022, LANL will not operate facilities containing CAT I/II quantities of SNM. The location and operator of the consolidated plutonium center will be determined following completion of appropriate National Environmental Policy Act (NEPA) reviews." NNSA would "Plan, construct, and startup a consolidated plutonium center for long-term R&D, surveillance, and manufacturing operations. Plan the consolidated plutonium center for a baseline capacity of 125 units [i.e., pits] per year net to the stockpile by 2022." NNSA would "Upgrade LANL plutonium facilities at Technical Area 55 to support an interim production rate of 30 to 50 RRW war reserve pits per year net to the stockpile by 2012." Regarding another building, NNSA would "Complete and operate the Chemistry and Metallurgy Research Replacement (CMRR) as a CAT I/II facility up to 2022 (use as a CAT III/IV facility and focal point and for material science thereafter) to support plutonium operations at LANL, closure of existing LANL Chemistry and Metallurgy Research (CMR) facility, and the removal of CAT I/II quantities of plutonium from LLNL [Lawrence Livermore National Laboratory]."
Importantly, the plan for Complex 21 shifted capacity from a range of 125 to 450 ppy examined in the MPF EIS to a baseline of 125 ppy.
section_title: Chemistry and Metallurgy Research Replacement Project
paragraphs: While nuclear weapons production was at issue, so was R&D on SNM, with a focus at LANL on plutonium. The CMR building had significant problems due to aging and design. As described in a Government Accountability Office report of 2013,
DOE's and NNSA's plans for replacing the CMR have changed over the past several decades. In 1983, DOE first decided that the CMR was outdated and began making plans to replace it. Over the next nearly 2 decades, several large replacement projects were proposed, but none progressed beyond conceptual stages. … NNSA has taken a number of steps to develop the CMRR nuclear facility or some facility to replace the CMR, but its plans have continued to change over time.
One such project was the Special Nuclear Materials Research and Development Laboratory Replacement Project at LANL. It would have replaced CMR, and would have included a laboratory and facilities for laboratory support, offices, utilities, and waste pretreatment. According to a LANL document of 1990, funding was $10 million for FY1988 and $22 million for FY1989. Anticipated milestones included completion of preliminary design in January 1990, completion of an EIS in 1991, site work start in mid-1991, and construction completed in the fall of 1994.
This project did not happen. Instead, it eventually morphed into the Chemistry and Metallurgy Research Replacement (CMRR) project. In 2002, NNSA reached Critical Decision 0, approve mission need, for the project. In 2003, NNSA completed an environmental impact statement on the project, and in 2004 NNSA issued a Record of Decision (ROD) on it. The preferred option in the ROD included two buildings. The Chemistry and Metallurgy Research Replacement Nuclear Facility (CMRR-NF) was to be a laboratory building that would have provided support, such as AC, for pit production. A separate building, RLUOB, would have provided offices, utilities for both buildings, and laboratory space for R&D. Because the amount of plutonium RLUOB would have held under then-current regulations was so small, at most 6 grams of WGPu, it was expected to do only a small amount of AC to support weapons production work. In 2005, "NNSA authorized the preliminary design (Critical Decision 1 or CD-1) for the CMRR project." In 2008, NNSA issued an ROD to keep plutonium manufacturing and R&D at Los Alamos and to build CMRR-NF there to support these tasks. RLUOB was completed in FY2010, but CMRR-NF was still in preliminary design at that time.
Congress initially approved the project, but concerns grew as the cost escalated and the schedule slipped. Concurrently, the need to replace CMR became more urgent. Michael Anastasio, then Director of LANL, testified that CMR "is at the end of its useful life," that CMRR "is critical to sustaining the nation's nuclear deterrent" and to other missions, and that "to successfully deliver this project, it will be important to have certainty in funding and consistency of requirements throughout the project." Also, as noted earlier, CMR was "decrepit" and not seismically robust. In an effort to secure Senate approval of the New START Treaty, the Administration issued a report in November 2010 stating that it "is committed to fully fund the construction of the Uranium Processing Facility (UPF) and the Chemistry and Metallurgy Research Replacement (CMRR)" and set out a 10-year funding profile for both facilities. The New START resolution of ratification included provisions related to the nuclear weapons complex in general and to CMRR and UPF in particular. The Administration requested the amount indicated in its November 2010 report in the FY2012 budget. However, in the FY2013 request, the Administration eliminated funding for CMRR-NF and "deferred" it "for at least five years" on grounds that the CMRR facility, UPF, and a life extension project for the B61 bomb were unaffordable concurrently and that there were alternative ways of accomplishing the tasks that CMRR-NF was to perform. However, Section 3114 of the FY2013 National Defense Authorization Act ( P.L. 112-239 ) directed the Secretary of Energy to "construct at Los Alamos National Laboratory, New Mexico, a building to replace the functions of the existing Chemistry and Metallurgy Research Building at Los Alamos National Laboratory associated with Department of Energy Hazard Category 2 special nuclear material operations." This provision also barred any funds to be spent on a plutonium strategy for NNSA "that does not include achieving full operational capability of the replacement project by December 31, 2026." However, Congress appropriated no funds for CMRR-NF for FY2013. 
For FY2014, the Administration requested no funds for CMRR-NF, and Congress authorized and appropriated no funds for it. However, Section 3117 of the FY2014 National Defense Authorization Act ( H.R. 3304 , P.L. 113-66 ) included an exception to the plutonium strategy provision just noted. It authorized NNSA to spend funds on a modular building strategy, that is, "constructing a series of modular structures, each of which is fully useable, to complement the function of the plutonium facility (PF–4) at Los Alamos National Laboratory, New Mexico, in accordance with all applicable safety and security standards of the Department of Energy." Option 12 describes the modular strategy.
section_title: Two Other Failed Attempts
paragraphs: As a further illustration of difficulties in building facilities to handle plutonium, this section presents two facilities that were built, found to be unusable, and demolished.
Nuclear Materials Storage Facility (NMSF): This building was built at LANL. According to the DOE FY1984 budget request, "This project provides for the construction of a repository for long and intermediate storage of large quantities of source and special nuclear materials. It will be designed to meet security, safety, and safeguards requirements for the storage and handling of nuclear materials. The new 29,100-square-foot building will contain a vault area of approximately 13,000 square feet." A 1997 report by the DOE Inspector General was scathing:
We found that the NMSF, which was originally completed in 1987, was so poorly designed and constructed that it was never usable and that DOE officials were proposing to renovate the entire facility. Departmental and contractor officials discovered numerous design, construction and operational deficiencies after the facility was occupied in February 1987. These deficiencies included: (1) the inability to control and balance the heating, ventilation and air conditioning (HVAC) system to maintain acceptable negative pressures within the facility; (2) the inability to dissipate the heat generated by radioactive decay of the materials to be stored; (3) the inability to limit personnel radiation exposures to "as low as reasonably achievable;" (4) a peeling of the "Placite" decontamination epoxy coating throughout the facility; and (5) the inability to open and secure the Safe Secure Trailer (SST) doors due to the inadequate width of the garage once the SSTs were parked in the garage.
Because of these and other deficiencies, "This structure was never used for storage of nuclear materials, and a decision was made in 2006 to demolish the structure." Demolition was completed by the end of FY2008.
Building 371: A press report tells the story of a plutonium project at Rocky Flats:
One striking example of a construction project that turned out to be a failure was a $225 million plutonium processing building at the Rocky Flats Plant near Golden, Colo. The processing plant, Building 371, was started in 1973, completed in 1981 and operated for a month in 1982 before being shut because the new processing technology did not work. The Energy Department has estimated that it will cost nearly $400 million and take eight years to make the equipment in the building work.
"The fact of the matter is that Building 371 is a fiasco," said Joseph F. Salgado, the Deputy Secretary of Energy. "It's a horror story. It's unacceptable."
Building 371 was intended to replace another, much older processing plant, Building 771. … The Energy Department shut Building 771 on Oct. 8 after three employees were exposed to plutonium dust, which can be extremely dangerous if it is inhaled. The closing of Building 771 was, [sic] the nation's sole source of reprocessed plutonium, which is used in triggers for thermonuclear bombs. The closing has brought most of the plant's operations at the Rocky Flats Plant to a halt.
The building was never put into operation. Instead, the buildings at Rocky Flats Plant, including Building 371, were torn down and the site was decontaminated.
section_title: Options for Congress
subsections: section_title: Analysis of Alternatives
paragraphs: For many years, Congress has been concerned with cost growth and schedule delays in nuclear weapons complex programs for facilities and weapons. One way to help resolve this problem may be to have a thorough airing of alternatives before decisions are made. Most recently, in its work on the FY2014 budget, Congress pressed NNSA to analyze alternatives:
The Senate Armed Services Committee noted that "NNSA spent about 10 years and more than $350 million on the design of the CMRR Nuclear Facility" before it was deferred and a larger amount on another project that was canceled. The committee stated that "these decisions raise serious questions about how well NNSA scrutinizes the analyses of alternatives prior to submitting them for review and approval." Accordingly, it directed GAO to study, among other things, NNSA's process for analyzing alternatives.
The House Armed Services Committee, in its report on H.R. 1960 , the FY2014 defense authorization bill, stated that Section 3113 would "require the Secretary of Energy, acting through the [NNSA] Administrator, to request an independent review of each guidance issued for the analysis of alternatives for each nuclear weapon system undergoing life extension and each new nuclear facility of the nuclear security enterprise as well as the results of such analysis of alternatives. The Secretary of Energy, acting through the Administrator, would be required to submit the results of any such analysis to the Nuclear Weapons Council and the congressional defense committees." Section 3113 also "would express the sense of Congress that Congress encourages the Administrator and the Nuclear Weapons Council to follow the results of the analysis of alternatives of a life extension program or a defense nuclear facility construction project when selecting a final option." This provision was included in H.R. 1960 as passed by the House. Section 3112 of the FY2014 National Defense Authorization Act ( H.R. 3304 , P.L. 113-66 ) contained related language.
Section 311 of H.R. 2609 , the FY2014 energy and water development appropriations bill as passed by the House, directs the Secretary of Energy to submit "a report which provides an analysis of alternatives for each major warhead refurbishment program that reaches [a certain stage]."
The Senate Appropriations Committee expressed its concern "about NNSA's ability to assess alternatives, which may significantly reduce cost, at the preliminary planning stages of a project." It referred to the deferral of CMRR-NF and the cancellation of another project, each incurring planning costs of hundreds of millions of dollars, and noted, "The Committee believes this wasteful spending could have been avoided had NNSA better assessed alternatives." Accordingly, it directed NNSA to submit a plan on how NNSA "will strengthen its ability to assess alternatives."
Section 312 of the FY2014 Consolidated Appropriations Act ( H.R. 3547 , P.L. 113-76 ) requires the Secretary of Energy to submit to Congress an analysis of alternatives for the B61-12 LEP and certain other major warhead refurbishment programs.
subsections: section_title: The Role of the National Environmental Protection Act (NEPA) Process in an Analysis of Alternatives
paragraphs: Over the past several decades, many projects, including some in the nuclear weapons complex, have been delayed or stopped by lawsuits brought by nongovernmental organizations under the National Environmental Policy Act (NEPA) of 1969, P.L. 91-140, as amended. These lawsuits typically involve procedural issues of compliance with NEPA in preparing an environmental impact statement (EIS). For example, plaintiffs might charge that an agency filed an inadequate EIS or did not consider all reasonable alternatives adequately.
Secretary of Energy Steven Chu stressed the importance for DOE of complying with NEPA:
Compliance with the National Environmental Policy Act (NEPA) is a pre-requisite to successful implementation of DOE programs and projects. Moreover, the NEPA process is a valuable planning tool and provides an opportunity to improve the quality of DOE's decisions and build public trust. Hence, timely attention to NEPA compliance is critical to accomplishing our missions. …
I cannot overstate the importance of integrating the NEPA compliance process with program and project management and of applying best management practices to NEPA compliance in DOE," and pointed to the DOE NEPA Order as a "[tool] available to help improve the efficiency of its NEPA compliance efforts.
Several options discussed below involve increasing the amount of plutonium in RLUOB beyond that permitted for a Radiological Facility so it could perform the AC needed to support production of 80 ppy. Section 102 of NEPA would seem to require an EIS for those options because the increase could raise the risk to the "human environment" in a major accident. Section 102 directs all federal agencies to 
(C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on—
(i) the environmental impact of the proposed action, 
(ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, 
(iii) alternatives to the proposed action, 
(iv) the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity, and 
(v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. 
In 2008, NNSA prepared a broad ("site-wide") EIS for LANL that included the plutonium program there. Given the state of flux of the plutonium program, NNSA has not prepared an EIS on it since then, though in 2011 it prepared a Supplemental EIS narrowly focused on the CMRR-NF component of the CMRR project. 
However, Greg Mello, Executive Director of Los Alamos Study Group, a nongovernmental organization, argues that "an EIS must precede NNSA's choice between post-CMRR-NF plutonium sustainment alternatives." He prepared the following analysis in August 2013 for this report. Since the study group has filed four NEPA lawsuits against Los Alamos construction projects over the past two decades, this analysis merits particular attention.
The main elements of the NEPA landscape are (1) a statute that elevates environmental values to a major purpose of governance, establishes a procedural approach to integrating those values in decisions, and creates a Council on Environmental Quality (CEQ) to oversee this process; (2) CEQ regulations that are binding on agencies; (3) agency regulations, harmonious with CEQ's but tailored to each agency; (4) CEQ guidance that lacks the force of law but is frequently cited by courts; and (5) a body of case law, based on thousands of cases, that creates a sort of NEPA "common law"—some universally binding, some binding in some federal districts, and some influential for such reasons as lucidity. Early NEPA case law established some basic parameters of implementation, such as that citizens could sue agencies to enforce NEPA compliance. Over time, a body of NEPA law has developed that is relatively settled for most basic legal issues but contested in other areas, especially where decisions depend on particular facts. 
DOE requires an EIS and a Record of Decision (ROD) as early steps for all major projects that may have significant impacts. In the case of CMRR-NF, a careful EIS that really compared alternatives realistically would have noticed the earthquake-amplifying stratum of volcanic ash beneath the site and incorporated the latest seismic information, problems that later bedeviled the project. The underlying weaknesses in purpose and need could have been vetted as well, and hundreds of millions of dollars in design costs and many years of delay in acquiring safer plutonium capabilities could have been avoided. Sound EISs and formal RODs would strengthen DOE's project management.
I believe that an EIS must precede NNSA's choice between post-CMRR-NF plutonium sustainment alternatives. An EIS requires objective environmental analysis of all reasonable alternatives prior to actions that irreversibly commit federal resources or bias the agency toward an alternative, with an initial business-case analysis used to establish which alternatives are reasonable. Because NNSA has proposed alternatives to CMRR-NF that are major federal actions that could have significant effects on the human environment, and since NNSA has no EIS that analyzes the impact of these alternatives, NNSA must initiate an EIS to do so. Some proposed CMRR-NF alternatives encompass multiple states and sites and may cost billions of dollars. All alternatives will have significant environmental impacts over much of this century. 
The relative environmental benignity of upgrading RLUOB to an HC-3 facility might tilt the scales toward that choice but is not a reason not to do an EIS. Upgrading RLUOB may not be the whole of the post-CMRR-NF redirection in plutonium programs. Other nuclear weapons complex sites are under consideration for involvement, including [Lawrence Livermore National Laboratory, Nevada National Security Site, Waste Isolation Pilot Plant], and perhaps [Savannah River Site]. LANL is also considering building "modular" plutonium facilities and is actively briefing this option to Congress. An EIS is definitely required for choices of this magnitude. None of these alternatives, let alone "all reasonable alternatives" as the law requires, have been weighed and their impacts compared in any EIS. Furthermore, NEPA's regulations and case law are clear that an agency cannot analyze one project's alternatives and build something quite different, or take one action today and significantly add to that action later, or do so contemporaneously with separate but connected projects. Congress has been anxious to see a formal plan for plutonium sustainment; the formality of NEPA process would help provide that plan while also serving as a barrier to "scope creep" and associated cost escalation.
It cannot be overemphasized that NEPA's analysis of alternatives serves public purposes beyond environmental ones. As John Immele, former director of LANL's nuclear weapons program, wrote in late 1999 regarding the NEPA process, "A ... lesson from the weapons program of the early and mid 1990s as well as the fissile materials disposition program is the necessity for and (surprising) success of publicly vetting our strategies through environmental impact statements."
A thorough EIS analysis of plutonium program alternatives would be a way of complying with NEPA, would be responsive to congressional desires to have NNSA analyze alternatives, would reduce the likelihood that lawsuits filed to challenge the alternative chosen would succeed, and would thus reduce the likelihood that such lawsuits would be filed.
section_title: Potential Options
paragraphs: Many options are possible. Ideally, all would meet multiple, and sometimes conflicting, goals, such as:
Support production of 80 ppy. Support all other necessary plutonium work, however "necessary" is defined. Examples might include ARIES, producing plutonium-238 sources, conducting plutonium R&D, and processing liquid waste containing plutonium in order to reduce its volume for shipment to WIPP. Reduce safety and security risks (building collapse in an earthquake or other disaster, dose to workers and the public resulting from an accident, terrorist attack leading to detonation of a nuclear device, etc.) to an acceptably low level. Maximize cost-effectiveness and ensure affordability. Complete the project on a schedule that supports needed work. Halt program operations in CMR in approximately 2019. Provide a planning margin for the facility to meet, in the future, new or expanded missions or more stringent regulatory requirements. Maximize useful life of the facility or facilities. Comply with all existing regulations.
Clearly, the more requirements that are levied on a project, the harder it is to comply with them all. In this case, none of the options presented here could meet all these goals simultaneously, and in some cases there is little or no data to evaluate how well an option would meet its goals. Thus Congress is faced with a choice among imperfect options.
The following list includes a broad spectrum of options. The list is presented as a progression, with a logical connection from one option to the next. Each connection is shown in italics.
As a start, consider options using existing buildings at Los Alamos, home to the only U.S. pit manufacturing capability . Since RLUOB is permitted to hold only a few grams of plutonium and CMR is at considerable seismic risk and due to be closed out, why not …
subsections: section_title: Option 1. Focus PF-4 on Pit Production; Move Other Tasks Elsewhere as Needed
paragraphs: PF-4 has enough lab space, about 60,000 sf, to produce about 10 ppy with RLUOB supporting some low-MAR AC. LANL estimates that PF-4 could be used to manufacture 30 ppy without having to move out any ongoing programs. Attaining this higher capacity would require several actions including reconfiguring existing space and "invest[ing] in new equipment (acquire/install) to increase capacity to 30 pits per year." As a hedge against inadequate plutonium processing capacity, NNSA's Plutonium Metal Processing subprogram would process plutonium alloy from pits returned from Pantex so as to create an inventory of metal for pits before it is needed; doing so "helps ease constraints on Analytical Chemistry (AC) capacity and reduce out-year risk to achieve capacity targets." Both of these activities serve to increase pit-manufacturing capacity without requiring additional laboratory space.
Furthermore, NNSA's plutonium strategy is considering ways to make better use of space in PF-4 and RLUOB to support the transition of AC and MC capabilities from CMR. Some space would be made available for this transition by reclaiming or "repurposing" rooms in PF-4 that are no longer in use (e.g., because the projects they housed have been completed), and some would come from reconfiguration, that is, rearranging equipment to increase efficiency. The former would add net space for AC/MC; the latter would not. AC equipment also would be added in RLUOB. In total, these actions would affect 8,000 sf in PF-4. A Los Alamos study considered using a facility at Livermore (see Option 7) and RLUOB for AC but did not consider having PF-4 perform all the AC work itself. In part this is because AC is space-intensive and PF-4 would not have sufficient space for production of 30 ppy plus the AC needed to support that capacity.
AC would pose this problem because PF-4 is not configured for a large amount of AC. While some AC operations that use gram quantities of plutonium can be performed in gloveboxes, most AC operations use tiny samples, such as milligram or microgram quantities of plutonium dissolved in acid and placed in very small containers. Manipulating them is much easier in open-front hoods using thin gloves; it would be much harder to manipulate these samples with the multiple layers of gloves required for PF-4 glovebox work. However, hoods require a powerful ventilation system to create negative pressure in the hoods (so no fumes or plutonium escape), and multiple large HEPA filters. Gloveboxes require much less ventilation capacity since any air that flows into them does so through small leaks. PF-4, which is mostly outfitted with gloveboxes, does not have sufficient air handling capacity to support the hoods needed for 30 ppy. It would be difficult to replace gloveboxes with open-front hoods in PF-4 because the PF-4 ventilation system was not configured for the large airflow that hoods require. Upgrading PF-4 ventilation to support the large number of hoods needed to provide high AC capacity would at best be extremely costly. Indeed, the ventilation system to support open-front hoods is so bulky, as shown in Figure 6 , that it might not be possible to retrofit it into PF-4 at any cost. By extension, even if all of PF-4 were devoted to pit manufacture and supporting tasks, it appears highly improbable that PF-4, by itself, could do all the work needed to produce 80 ppy. There would also be the issue of where to house the tasks that would be moved out. 
Given those problems, why not …
section_title: Option 2. Build CMRR-NF
paragraphs: Another option is to resume work on CMRR-NF. That building, after all, was not canceled—it was merely "deferred" for "at least five years." Los Alamos estimates that if construction were to begin in FY2018, the building would be completed in 2029, with the five-year delay adding another two years to construction time due to the need to assemble crews, let contracts, etc. Even so, this completion date would be in time for CMRR-NF to contribute to reaching the goal of producing 80 pits per year by 2030. CMRR-NF would provide HC-2 space for AC and MC in support of weapons production. While it is not at all certain that the facility will be built, it could be built if Congress chose to provide funding for it.
This option faces many difficulties. The conditions that led the Administration to defer CMRR-NF in FY2013 remain in place, and in some cases have arguably become more salient since then. 
In deferring CMRR-NF, the Administration argued that building UPF and CMRR-NF and beginning the B61-12 LEP simultaneously would be unaffordable, and that available options would enable the nuclear weapons complex to perform the tasks of CMRR-NF.
The cost of UPF has increased and its schedule has slipped, possibly necessitating a scaled-back version of UPF. This adds weight to the Administration's judgment about the affordability of CMRR-NF, UPF, and the B61-12 LEP if done simultaneously.
Section 3114 of the National Defense Authorization Act for FY2013, P.L. 112-239 , required the Secretary of Energy to construct, at Los Alamos, "a building to replace the functions of the existing Chemistry and Metallurgy Research Building at Los Alamos National Laboratory associated with Department of Energy Hazard Category 2 special nuclear material operations." However, NNSA requested no funds for CMRR-NF in FY2013 or FY2014, and Congress appropriated no funds for it in those years.
As detailed in P.L. 113-66 , FY2014 National Defense Authorization Act, Section 3117, "Authorization of Modular Building Strategy as an Alternative to the Replacement Project for the Chemistry and Metallurgy Research Building, Los Alamos National Laboratory, New Mexico," Congress is willing to consider modules (see Option 12) as an alternative to CMRR-NF. (Note that modules would perform high-MAR work while CMRR-NF would have performed mainly AC, which involves much less MAR.)
A modified RLUOB that could "perform the functions of the existing Chemistry and Metallurgy Research Building," as discussed under Options 8-10, would meet most of the functionality requirement of Section 3114 of P.L. 112-239 , though not the requirement for a new building. (It would not provide vault space, as CMRR-NF would have, but it appears that the PF-4 vault will suffice, as discussed in " Options 6-12 Overview: Matching Plutonium Tasks to Buildings .")
By the time construction could resume on CMRR-NF, other options, such as those the Administration was considering, would presumably be well developed, reducing the added value of CMRR-NF.
Congress expressed concern over the escalating cost and delays of CMRR-NF, going so far as to impose cost and schedule caps on the project in Section 3114; would Congress be confident that NNSA could bring CMRR-NF online on schedule and on budget?
But even building CMRR-NF would not address the fact that PF-4 would be over 50 years old when CMRR-NF came online, leaving aging and seismic issues unresolved. It may be possible to resolve them with another option …
section_title: Option 3. Build a New Building Combining PF-4 and CMRR-NF Functions at LANL
paragraphs: A new building could combine the functions of PF-4 and CMRR-NF. The argument for this option is that PF-4 will be 50 years old in 2028, about when CMRR-NF could be completed. Combining the two buildings into one would presumably cost less than building two separate buildings and would avoid the need to transfer material between buildings, increasing efficiency. A new building would incorporate the most advanced techniques to minimize seismic risk.
This option encounters many difficulties. The building would be larger and more complex than either of the two smaller buildings, and complexity in a major nuclear construction project could be expected to drive up costs and stretch out the schedule. Whereas CMRR-NF design work is nearly completed, the new building would have to be designed from scratch, adding time and cost. Also at issue is the need for this facility. NNSA's TA-55 Reinvestment Project (TRP) plans to extend PF-4's life to approximately 2039, so combining the two buildings would forgo a decade of PF-4 useful life. TRP cannot be halted on the chance that the new building would be built: given the immense difficulties that earlier large facilities have encountered, there is no assurance that the new building would be built. Some key nuclear facilities, notably Building 9212 and CMR, have service lives of over 60 years. RLUOB, too, should have at least a 50-year life, that is, to 2059, since it was built to much higher standards than CMR or Building 9212. Upgrades could presumably extend its life. If RLUOB and PF-4 together can do the necessary plutonium work for at least another quarter-century, it would seem premature to even start planning a replacement facility now.
Despite advances in design and construction that reduce seismic risk, this building would still be at some risk from an earthquake if sited at Los Alamos . A simple way to avoid this risk is to …
section_title: Option 4. Build a Building Combining PF-4 and CMRR-NF Functions at Another Site
paragraphs: Constructing this building at a nuclear weapons complex site other than LANL with low seismic risk, such as Pantex, would solve seismic issues regarding LANL, although the Virginia earthquake of 2011 raises doubts about the seismicity of any site. The difficulty lies in the tradeoff. LANL has a large human and facility infrastructure for plutonium work; much of that would have to be built from scratch at Pantex Plant (TX), the nuclear weapons complex site that performs final assembly and initial disassembly of nuclear weapons, taking considerable time and involving considerable expense. Savannah River Site has a plutonium waste infrastructure, but not the equipment or personnel for weapons manufacture. Its seismicity is in the same range as that of Los Alamos. Further, while the regulatory issues of dealing with plutonium buildings are well known for LANL, they would have to be examined in detail at another site. Siting, permitting, and preparing an EIS would be time-consuming. In addition, this option would not resolve problems with design, construction, and cost of the building itself.
If building a new building at another site has problems, what about using another existing building at LANL …
section_title: Option 5. Refurbish the Chemistry and Metallurgy Research (CMR) Facility
paragraphs: CMR currently performs some AC for pit production in PF-4, as well as nuclear forensics. Given that these are the only two facilities at Los Alamos contributing to pit production, and that it will be many years before a new one could be built, CMR is being maintained at a minimal level in order to keep it operational until approximately 2019, at which point NNSA plans to halt plutonium work there. One option would go beyond currently planned maintenance and upgrades so as to keep it in operation longer. Just as PF-4 is being upgraded on an ongoing basis to reduce the risks of building collapse and fire, keeping it in operation until 2039, more substantial upgrades to CMR might in theory keep it in service well beyond 2019. So doing would provide AC and other capability until a new building could be built.
This option has many problems and uncertainties. As noted, a congressional commission called CMR "genuinely decrepit" and a DNFSB study found it to be "structurally unsound." Multiple wings of the building have been stripped to bare walls and floors to reduce nuclear material and prepare for decommissioning. A manager at Los Alamos indicated that CMR was built to the standards of the 1950s and there is a "vast mismatch" between the safety requirements of then and now. This individual pointed to problems with heating, electrical, and ventilation systems, and stated that refurbishing the ductwork would be "cost-prohibitive." A tour of the building in September 2013 by the author revealed drains that had been concreted shut, gloveboxes with plastic bags instead of drain connections, gloveboxes with little to no anchoring to the floor, patches to pipes to keep them in operation, and water leaks in the ceiling. Laboratory staff stated that utility panels behind walls were contaminated with radioactive material and that corrosion in some piping had greatly reduced the inside diameter. Since NNSA plans to halt CMR operations in approximately 2019, there have been no studies of how to extend its service life well beyond that time, or what it would cost to do so. However, the fatal flaw in this option is that CMR lacks seismic robustness. Given these problems, it appears that retrofitting CMR to provide adequate utility and seismic robustness may not be possible at any reasonable cost.
Despite these problems, if no other facility is ready to do the work of CMR by 2019, there would appear to be no other option than keeping CMR operational beyond that date, which would entail additional costs, inefficiencies, and the risk of keeping workers in a seismically fragile structure.
Given problems with some obvious options, are other options available? A logical construct matching tasks to buildings may help …
section_title: Options 6-12 Overview: Matching Plutonium Tasks to Buildings
paragraphs: As Table 2 shows, plutonium work may be divided into tasks requiring low or high security, and tasks involving lower- or higher-hazard quantities of MAR. This overview discusses each cell.
High SC/High HC: Most work on pits, whether fabricating them using foundries, performing such supporting tasks as sample prep and some MC, or destroying them using ARIES, involves large amounts of WGPu in a form that could be immediately usable by terrorists. As such, this work requires high security and high MAR. PF-4 is HC-2/SC-I, and has the necessary equipment and supporting infrastructure for pit work. PF-4 is the only building in the nuclear weapons complex with this combination of attributes. Therefore, the most efficient use of PF-4 is for tasks requiring high MAR and high security. As a corollary, pit production capacity and efficiency can be increased by moving tasks that do not require high MAR and high security out of PF-4.
Low SC/High HC: Producing 80 ppy would require casting more hemishells, increasing MAR substantially. While LANL has not done a detailed analysis, this added MAR could raise PF-4 above the limit allowed by the Documented Safety Analysis unless countervailing steps are taken. One approach, discussed in Option 12, would be to build a new module at LANL to hold the pit foundry. A second approach, discussed in Options 6 and 12, is to move Pu-238 work out of PF-4 to a module at LANL or to another site. Pu-238 is an ideal "candidate" to be moved out of PF-4. It is 275 times as radioactive as Pu-239, and even though it is a small fraction of plutonium by weight in PF-4, it accounts for 40% of its MAR allowance. It is in a low security category because it would be unattractive to terrorists. Moving Pu-238 out of PF-4 would also free up 8,000 sf of floor space, which could be made available for pit work.
Low SC/Low HC: Casting hemishells for 80 ppy would also require increasing floor space dedicated to that task. AC is floor-space intensive. At the same time, it involves low MAR; indeed, the MAR is so low, and the form of the material (typically tiny samples of plutonium dissolved in acid) of so little value for use in a nuclear weapon if captured by terrorists, that much less security is required than PF-4 provides. The same holds for MC using samples of several grams of metallic plutonium. Accordingly, AC and some MC can be performed in SC-III/IV buildings. Thus, floor space could be made available in PF-4 by performing AC and some MC elsewhere. Manufacturing 10 ppy in PF-4 would have required 2,400 sf of floor space for AC in PF-4, plus about 7,000 sf for AC in RLUOB. The amount in PF-4, 2,400 sf, is a small fraction of that building's space, but since AC for 80 ppy would require considerably more floor space and ventilation capacity, the key value of conducting AC elsewhere would be in keeping additional AC from moving into PF-4. Options for moving AC out of PF-4 are discussed in Options 7-11. Moving the PF-4 gas gun (see Figure 12 ) out of that building and into a building for AC would release 1,200 sf of floor space, and a small amount of MAR, from PF-4.
In sum, moving (and keeping) AC and some MC out of PF-4 would free up space but little MAR, while moving Pu-238 out of PF-4 would free up substantial space and MAR. In combination, these measures would free up much space and MAR in PF-4, making it more likely that it could produce 80 ppy and conduct other plutonium work.
High SC/Low HC: This is a null set; no plutonium tasks require high security for low MAR.
A note on vault storage space: A vault for storing plutonium is an integral part of pit production. It acts as a buffer to hold plutonium because one production task may not dovetail precisely with another. For example, pit production requires a place to hold plutonium metal that has been qualified for use in pits until it is needed, to hold hemishells until they can be joined into completed pits, and to hold completed pits until they are shipped to Pantex for incorporation into weapons. A vault is also needed to store pits from weapons that have been returned from deployment sites for surveillance. PF-4 is the only building at Los Alamos with a vault qualified to hold the large quantity of plutonium that such tasks require.
When CMRR-NF was being designed in the early 2000s, SNM vault space at PF-4 and other sites was mostly filled and the final disposition of material from other sites was unknown. Accordingly, NNSA decided to add vault space to CMRR-NF. RLUOB could not have a vault because it was designed as a Radiological Facility. At issue is whether there is enough vault space in PF-4 to support production of 80 ppy.
Over many years, the PF-4 vault has accumulated much material that is no longer needed for programmatic operations. Some, in excess to current or foreseeable needs, can be de-acquisitioned and shipped to the Waste Isolation Pilot Plant for permanent disposal, to Savannah River Site for other disposition, or to Y-12 for uranium items. Plutonium that might be needed for future operations could be stored elsewhere, such as Pantex Plant, which stores thousands of pits, or the Device Assembly Facility at the Nevada National Security Site, an HC-2/SC-I facility that has space available for storage of plutonium, or the K Reactor at Savannah River Site, which is currently used to store plutonium. Thus there are many ways to reduce the amount of material stored in the PF-4 vault, and NNSA accelerated vault cleanout as a mitigation effort associated with the deferral of CMRR-NF. Cleaning out the vault at PF-4 will make more room available for plutonium needed for production. LANL has not studied whether cleanout would provide enough space to support production of 80 ppy, but it appears likely that an effort focused on this goal and coordinated with other sites could do so. Since additional PF-4 vault space could readily be made available and it is not known how much would be needed to support production of 80 ppy, this report does not discuss increasing available vault space as a separate option.
As a first step in moving through the options presented in Table 2 , perhaps NNSA could …
section_title: Option 6: Conduct Plutonium-238 Work at INL or SRS
paragraphs: Pu-238 accounts for 40% of the MAR allowance at PF-4. Increasing pit production to 80 pits per year (ppy) would increase MAR, and the increased pit foundry work, combined with Pu-238 work and other work, could exceed the MAR limit permitted for PF-4. One option would be to move Pu-238 work out of PF-4, whether to a module connected to PF-4 or to another site. While LANL is DOE's center of excellence for plutonium, Pu-238 work is readily separable from Pu-239 work because the two isotopes have very different properties and applications. Pu-239 is used in weapons and might be used as mixed oxide fuel (a mixture of oxides of Pu-239 and uranium isotopes) for nuclear power reactors, while kilogram quantities of Pu-238 are used to generate heat for conversion to electric power for defense and space missions.
In a report of May 2013, DOE examined several options for processing Pu-238 for fabrication of radioisotope power systems. One was to upgrade the existing line in PF-4; however, this would not address the possibility of reducing Pu-238 MAR in order to release MAR for weapons work. The report also considered performing Pu-238 work at Idaho National Laboratory (INL) or Savannah River Site (SRS). It did not address the LANL proposal to build modules connected to PF-4, one of which might perform Pu-238 work.
INL currently conducts operations with clad heat sources of Pu-238. It operates the Space and Security Power Systems Facility, which further encapsulates the Pu-238 heat sources produced by LANL, mates them to the power systems that convert their heat to electric power, tests the resulting system, and delivers them to users.
INL states that all current LANL Pu-238 operations could be transferred to INL, such as recovery, purification, and source fabrication, and that INL would have a capacity of processing 5 kg per year. The option to bring Pu-238 source fabrication to INL would use an existing building, CPP-1634, that was built in 1993 as an HC-2 building and was since downgraded. It would have to be upgraded back to HC-2 in order to handle 5 kg of Pu-238 per year. INL would also build an addition to CPP-1634 that would more than double its size. The upgrade would require modifying the safety analysis report and upgrading the building's safety systems (such as ventilation) and equipment (such as gloveboxes) to be consistent with the hazards and operations proposed. Pu-238 in quantities of up to 16 kg is SC-III because it is unattractive for use in making a nuclear weapon. CPP-1634 would have more security than is needed to meet SC-III requirements because it would be within the INL security perimeter.
The DOE report noted several advantages of establishing this capability at INL, including a new design that minimizes down time and maintenance cost, and process improvements that minimize operational costs and worker exposure and improve product quality. Also, locating the program in a facility owned by DOE's Nuclear Energy program, which is responsible for plutonium-238, would allow "more control and lower operational costs as compared to operating within TA-55 that seems to have large overhead costs resulting in high operational costs." Drawbacks include "inexperience with Pu-238 processing operations," "loss of co-location and leveraging with related NNSA program," risk due to uncertainty in safety requirements because "no new Pu-238 processing facility has been constructed in many years," and "risk of moving Pu-238 operations away from DOE's plutonium operations center of excellence," that is, LANL.
There is also an SRS option. From the mid-1960s to early 1980s, SRS produced Pu-238 in its reactors by bombarding neptunium-237 target tubes with neutrons. It then dissolved the target tubes, separated and purified Pu-238 in H Canyon, turned the Pu-238 into plutonium oxide in HB-Line, pressed that material into heat sources, and clad them in iridium in the 235-F facility. In 1983, the last neptunium-237 targets were irradiated and in 1985-1986, Pu-238 operations were moved to LANL. Subsequently, the last SRS reactor was shut down in 1993. Work is underway to develop the capability to produce Pu-238 at Oak Ridge National Laboratory (TN).
SRS has two buildings that could be used for Pu-238. Its H Canyon is a large, highly shielded concrete structure, approximately 1,000 feet long by 120 feet wide by 75 feet high, that began operations in 1955. It was built to process irradiated targets and fuel rods from SRS reactors for various nuclear materials. These targets and fuel rods had very high levels of radioactivity, so they required processing in a facility that was heavily shielded and remotely operated. As such, it is off limits to personnel, and all material is processed by moving it through pipes or handling it with a remotely operated crane. It is the only remaining U.S. facility that is heavily shielded and remotely operated and that can chemically process large quantities of radioactive material, such as spent fuel rods. It is currently operational, processing irradiated fuel stored in an underwater pool at SRS. SRS also has the HB-Line, which is built atop H Canyon to provide a work space with heavily shielded gloveboxes for work on Pu-238. It became operational in the late 1980s. It is currently operating, but its Pu-238 lines would have to be restarted, which could take three or four years. A third building at SRS that was used in the Pu-238 program, Building 235-F, contained a process line that fabricated heat sources from Pu-238 oxide. However, the facility has not been operated since 1984 and is not part of the current proposal due to high levels of contamination.
In the SRS plan, Pu-238 could arrive at the plant as irradiated target tubes of neptunium-237 from a DOE reactor, as unpurified Pu-238 oxide from Russia, or as scrap Pu-238 oxide. These oxides would be dissolved in nitric acid in the HB-Line. This solution would be transferred through pipes to H Canyon, where it would be purified by removing other chemical elements. The purified Pu-238 solution would be transferred back to HB-Line, where plutonium would be precipitated out of solution and then turned into plutonium oxide, a solid. In an option in the SRS plan, a new Plutonium Testing and Processing Facility (PTPF), consisting of prefabricated hot cells (capable of handling highly radioactive material) and gloveboxes, would be installed in H Canyon. This facility would press plutonium oxide into pellets, which would be fabricated into heat sources, clad in iridium, and sent to INL, where they would be mated with power generating equipment and then delivered to end users.
The DOE report noted several advantages and disadvantages of this option. H Canyon and HB-Line can process a wide quantity range of Pu-238, from 1 to over 30 kg per year. These facilities are built to high safety standards. Infrastructure requirements are well understood, such as environment, safety, and health, material control and accountability, and waste management; there is also an AC capability. On the other hand, the length of time that missions will support H Canyon is not clear because "its mission length is defined by a campaign by campaign basis." Operations there are planned until 2018-2020, with operations beyond that time uncertain. 
Further, required production "[does] not necessitate a large throughput capacity. Thus, revitalization of the facilities may not be justified." And without a long-term mission, there is no clear advantage to building PTPF. At issue: There is value to the weapons program in removing Pu-238 from PF-4. Would processing Pu-238 be a long-term mission that would justify, and that might contribute funding to, PTPF?
The DOE report compared cost and schedule estimates for these two options, as follows. 
For the INL option, $12 million for technology development taking three years, and $110 million to $260 million for general-purpose heat source fabrication capability, taking five years. For the SRS option, $28 million to $45 million for plutonium purification revitalization, taking 3½ to 4½ years, and $125 million to $170 million for PTPF, taking four to five years. Combining these figures, the INL option would cost $122 million to $272 million and take eight years, and the SRS option would cost $153 million to $215 million and take 7½ to 9½ years.
It must be emphasized that these estimates are preliminary and are not based on extensive analysis.
DNFSB commented that "H-Canyon is exhibiting degradation of systems and structures that if not addressed, could challenge safe operations and pose a risk to facility workers. … DOE completed repairs to address some of the identified deficiencies … There are some safety-related repairs that have not yet been completed."
Having addressed Pu-238, this report now turns to options to address analytic al chemistry …
section_title: Option 7: Conduct Some or All Analytical Chemistry at LLNL or SRS
paragraphs: Lawrence Livermore National Laboratory (LLNL) has a large building, Building 332, that is part of its "Superblock" complex. Building 332 was built for plutonium work. One wing ("Increment 1") was built in 1961; another wing ("Increment 3") was built in 1975. Increments 1 and 3 are laboratory buildings; Increment 2 is the control room, without laboratory space. Building 332 was a Hazard Category 2/Security Category I facility, like PF-4, so it was used to handle hundreds of kilograms of plutonium. Its ventilation systems (including fans and HEPA filters) and electrical systems have been updated in the past decade. Even though Livermore is in a seismically active area, Building 332 was designed to take into account seismicity, and an analysis showed that it does not require an upgrade to make it more seismically robust. Its gloveboxes (new and retrofitted) are reinforced so as not to fall over in an earthquake.
Building 332 remains an HC-2 building, but its plutonium quantity is limited by its Security Category. It was SC-I. To reduce vulnerability and security costs, NNSA consolidated SNM to fewer facilities at fewer sites. As part of that plan, LLNL removed all SC-I/II quantities of SNM from the lab, a task completed in September 2012. Building 332 is now SC-III, which limits it, as a first approximation, to 400 g of plutonium metal and 16,000 g of plutonium in solution. Plutonium in solution poses much less risk—is less attractive to terrorists—than metallic plutonium, which is why much more plutonium is allowed in solution than in metal form.
Building 332 has ample space for AC work. It has 24,000 total sf of laboratory space, as compared to 19,500 sf for RLUOB and 22,500 sf in the CMRR-NF design. Some space is being used to fabricate plutonium samples for experiments that subject plutonium to impact (such as from a gas gun projectile) and for material processing studies. LLNL is currently using 5,000 sf for AC and MC, and could make another 6,000 sf available. Building 332 has a substantial excess of air handling capacity, which would support the use of open-front hoods. LLNL believes that Building 332 has sufficient air handling capacity to support AC for 80 ppy.
Once analyzed, samples would be processed as waste. For final disposition, waste is shipped to WIPP. Since WIPP does not accept liquids, liquid waste is solidified by mixing it with cement. LANL and LLNL differ in how they would handle waste. LANL has the capability to recover plutonium from liquid samples and to process the waste stream, solidifying it for shipment to WIPP. LANL uses AC to support these operations. LANL also uses AC to send liquid waste to LANL's Radioactive Liquid Waste Treatment Facility because that facility places requirements (such as the amount of mercury) in the waste it accepts for treatment. LLNL does not have these capabilities, and would not perform AC on material (liquids and solids) to be disposed of as waste. However, the liquid waste generated by the AC for 80 ppy would be very much less than the waste that LANL generates for various other missions, so LLNL holds that simply cementing the liquid waste would be a satisfactory way to prepare its liquid waste for shipping.
There are several potential drawbacks. All DOE sites that handle plutonium have their own AC operations rather than shipping samples to another site because AC is a basic capability required for many purposes in addition to pit manufacturing, such as measuring quantity of material for material control and accountability, recovering plutonium from waste streams, and for various types of pit work including development of processes for fabrication, qualification of processes, and certification. At issue is whether LLNL would have the needed capacity to support AC for 80 ppy while performing AC for other missions. Having LLNL perform the AC could add schedule risk to any LLNL program that needed AC.
While commercial carriers have shipped plutonium for some years, there might be public concern about shipping many hundreds of samples per year. As a related point, while LLNL could stay within MAR limits if plutonium shipments arrived weekly, a LANL engineer observed, "I have been associated with pit manufacturing for several decades and it hasn't ever reached steady state yet. The notion of standardized delivery dates is inconceivable to me. The manufacturing process is too fragile and is constantly interrupted leading to feast or famine sample delivery." Further, it takes five days to dissolve a certain type of plutonium samples (plutonium oxide fired at very high temperature). Might these problems result in exceeding MAR limits?
Performing all AC work in support of pit production would bring more plutonium work to LLNL. This would have the advantage of distributing plutonium expertise more widely in the nuclear weapons complex. LLNL currently has only four chemists doing AC on plutonium. This option would require adding staff and equipment, strengthening LLNL's capability, which could prove useful for peer review of plutonium issues as well as for AC. On the other hand, LANL is the center of excellence for plutonium in the nuclear weapons complex, and this option would dilute LANL's plutonium capability. According to a LANL staff member,
If all DOE sites were making steel, there would be ample opportunities to consolidate AC using commercial vendors. With plutonium, AC is too inherent to processing for one site to be completely reliant on off-site AC measurement. Manufacturing war reserve pits demands the highest quality level and the broadest suite of analytical techniques. Since LANL has the country's main plutonium facility, it would need substantial in-house AC capability, and there is inherent capacity in the capability. The logistics of a split-capability mission (manufacturing at LANL, AC elsewhere) does not seem amenable to a smoothly operating enterprise. That said, LANL's 2012 "60-day study" acknowledged that LLNL could perform some AC when LANL needed additional capacity.
Savannah River Site (SRS) offers another option. It has been involved with plutonium for many decades. It had five large reactors for producing plutonium, the first of which began operations in 1953. In total, these reactors produced 36 metric tons of plutonium, most of which was WGPu, with the largest annual amount, 2.1 metric tons, produced in 1964. All the plutonium produced had to be characterized, which required AC. Because SRS supplied plutonium to Rocky Flats Plant, SRS needed an industrial-scale AC capability to characterize the plutonium for the weapons program and to perform AC for other tasks, such as for Pu-238. Part of this capacity is currently unused, but SRS retains the infrastructure and equipment.
While SRS no longer produces plutonium—an SRS reactor last produced plutonium in 1988—SRS continues to conduct a great deal of plutonium AC. It has repurposed its K Reactor, which used to produce plutonium, to store tons of plutonium from across the nuclear weapons complex and elsewhere. For example, plutonium from Rocky Flats and the Hanford Reservation (which used to produce plutonium) was moved to the K Reactor, as was plutonium de-inventoried from LLNL in order to move Superblock to Security Category III, plutonium oxide produced from retired pits by ARIES at PF-4, and plutonium from foreign sources. More is being added on an ongoing basis. All this plutonium requires AC in order to characterize the isotopic composition and impurities of plutonium stored in drums at K Reactor. For example, AC would detect chlorides and fluorides in the plutonium mixture that would corrode storage drums. AC is also used for characterizing plutonium produced at HB-Line for use in mixed oxide (MOX, a blend of plutonium oxide and uranium oxide) fuel for nuclear reactors.
As with many industrial operations, SRS nuclear materials processing facilities operate 24/7, so SRS conducts AC 24/7 because some processing operations require a short turnaround time for AC, and personnel must be available at all times in case of problems.
SRS currently uses F/H Laboratory (the laboratory that supported H area, where H Canyon and HB-Line are located, and F area, which also has a canyon and a B-line) for AC. F/H Laboratory (see Figure 10 ) is large, 80,000 sf as compared to 60,000 sf for PF-4 and 19,500 sf for RLUOB. Also at SRS is Building 773-A, which is larger than F/H Laboratory. Since both labs were sized for a time when the United States produced many thousands of nuclear weapons, they have between them a great deal of excess capacity in terms of hoods and gloveboxes for AC. SRS believes that F/H Laboratory, with Building 773-A for redundancy or a spike in workload, could handle the AC for 80 ppy, though they would need some new instruments and SRS would have to hire perhaps 20 technicians and several analytical chemists. Both labs have a very large ventilation capacity. For example, F/H Laboratory is equipped with six large fans, but SRS calculated that two of them could be shut down and the others would still provide sufficient ventilation capacity. SRS could perform the AC and Pu-238 missions concurrently, as they would use different facilities—H Canyon and HB-Line for Pu-238, and F/H Laboratory, Building 773-A, or both for AC.
SRS has worked closely with LANL on AC. SRS is part of LANL's quality assurance program. LANL sends SRS metal samples once a year for SRS to perform AC on as part of the Plutonium Metal Standards Exchange. In that program, multiple sites, including the United Kingdom's Atomic Weapons Establishment, exchange plutonium samples and perform AC on them as a check on each other's AC capabilities. LANL, through its accreditation program, has also qualified SRS to perform the AC for plutonium to supply the MOX plant.
The drawbacks of conducting all AC for 80 ppy at SRS are similar to those discussed for LLNL, though LANL would not be opposed to conducting some AC at another site if it needed extra capacity to handle a spike in workload, or on a routine basis if production increased to 80 ppy.
Many plans proposed over the past two decades for plutonium work have sought to consolidate that work at a single site . If it is deemed desirable to do as much plutonium work as possible at LANL, what about a deeper look at other LANL options, starting with an existing building …
section_title: Option 8. Use RLUOB As Is for Analytical Chemistry, with PF-4 Conducting the Balance of Pit Work
paragraphs: Under this option, PF-4 would produce pits and would do sample preparation, waste disposal, and MC, while RLUOB would conduct AC on 26 g of WGPu, the most allowed by the Hazard Category material limit for a Radiological Facility. While RLUOB is ideally suited for AC, this option suffers from one significant flaw: 26 g of WGPu is nowhere near enough to do the AC to support 80 ppy, and PF-4 does not have the space to do most of the AC, all of the MC, all of the pit fabrication, other pit work, and work on other plutonium projects.
While RLUOB as is could not conduct the AC/MC needed under current regulat ions, would it be possible to …
section_title: Option 9. Convert RLUOB to Hazard Category 3 for Analytical Chemistry
paragraphs: Recently developed Los Alamos plans for PF-4 include upgrading wings of the building for Pu-238 operations, pit disassembly, pit fabrication, and other programs. Of particular importance are the upgrades to the pit fabrication wing of the building. These upgrades will remove currently unused gloveboxes from the manufacturing space, consolidate laboratory space, and improve the equipment layout to enhance process flow. These steps would increase PF-4's pit production capacity. CMR, RLUOB, or both would conduct some AC necessary to support pit manufacture.
Space consolidation offers an opportunity to repurpose space to add equipment to achieve capacities of up to 80 ppy for several, but not all, flowsheet operations. (A "flowsheet" is a sequence of operations that must be followed precisely to make a pit.) The capacity of other operations could be boosted in other ways, such as by adding shifts. The challenge is determining what actions are needed to ensure that every operation in the flowsheet could handle up to 80 pits per year because there is not enough space in PF-4 to scale all operations, including support operations like AC, up to a capacity of 80 ppy.
LANL has not analyzed space-fit issues for producing 80 ppy. But based on comparison to past analyses, it seems likely that achieving a capacity of 80 ppy in PF-4 is possible if LANL could fully use the laboratory space in RLUOB. The usefulness of that space, 19,500 square feet, is currently limited by a requirement that RLUOB can hold only 26 g of WGPu, the volume of two nickels. (See Figure 11 .) Increasing that limit to 1,000 g would provide enough MAR in RLUOB for the AC to support production of 80 ppy, as well as some MC. It is not clear that RLUOB has sufficient floor space to do that much work. However, as discussed in Appendix F , it seems likely that RLUOB with a MAR of 1,000 g WGPu, plus space made available in PF-4 through reconfiguration (8,000 sf) or by moving out Pu-238 (a separate 8,000 sf), plus improving pit fabrication operations (such as by using multiple shifts or improving efficiency of equipment or processes), would provide enough space and free up enough MAR to produce 80 ppy and to perform the AC needed to support that level of production.
To hold 1,000 g WGPu while complying with regulations, RLUOB would have to be converted to an HC-3 building. There are several advantages. So doing would support LANL's ability to perform the pit work that DOD requires. It would permit LANL to move AC equipment from CMR, enabling that building to halt plutonium operations. It would permit LANL to free up floor space in PF-4 by moving out equipment for AC and for some MC (see Figure 12 ), and to make operations more efficient, such as by moving out a large MC instrument now placed in the middle of an AC room.
A drawback is that it would take a substantial effort to convert RLUOB to HC-3. As a Radiological Facility, RLUOB is not subjected to federal, state, local, and laboratory requirements for an HC-3 building. To comply with these requirements, many tasks would have to be conducted; Appendix D lists about 100 of them. Many, such as preparing an environmental assessment and perhaps an EIS, developing safety design reports, developing engineering functions and requirements documents, developing an updated fire hazards analysis, and developing a final material control and accountability plan, would require much time and effort; others would require less effort. But the work would not stop with preparing these documents because many would lead to physical modifications to RLUOB. For example, an engineering 
task listed in Appendix D —"Develop design and analysis for seismic upgrades as required. RLUOB safety Structure, System and Components (SSCs) are not currently required to be operational following a seismic event per [NNSA's Los Alamos Field Office] direction"—could easily lead to seismic upgrades to RLUOB unless a decision were made to accept the risk in light of cost-benefit considerations.
LANL has not estimated the cost or schedule to complete these tasks, and the upgrade could prove to be expensive. However, given the historical record of cost growth, schedule delays, cancellations, and deferrals in constructing new plutonium facilities, upgrading RLUOB to HC-3 would probably be a quicker and less costly way to obtain the needed capacity than building a new building.
Regulations limit the quantity of WGPu that RLUOB can hold to the volume of two nickels . What would happen if that limit were not applied to RLUOB ?
section_title: Option 10. Use RLUOB, with Regulatory Relief, for Analytical Chemistry, with PF-4 Conducting the Balance of Pit Work
paragraphs: Many regulations impose burdens on the nuclear weapons complex, including plutonium facilities, that to some analysts may seem disconnected from end goals, such as reducing dose in the event of an accident to a level below a specified threshold. Two quotes are instructive; many more could be added. SEAB stated in 2005, 
The DOE has burdened the Complex with rules and regulations that focus on process rather than mission safety. Cost/benefit analysis and risk informed decisions are absent, resulting in a risk-averse posture at all management levels.
And an NNSA report of 2006 stated that the complex of that time had
A culture that sometimes seeks to eliminate all risks at an unsustainable cost no matter how small the probability of occurrence and to substitute oversight recommendations for responsible line decisions.
Hazard Category regulations limiting the amount of plutonium in a building are intended to limit the dose to emergency responders, collocated workers and the general public. However, a calculation in Appendix B shows that if RLUOB held 1,010 g of WGPu and a Design Basis Accident occurred in which the building collapsed, the dose for a collocated worker (CW) and a maximally-exposed offsite individual (MOI) would be far less than the guideline set forth in DOE regulations. Specifically, the dose to a CW would be 10.41 rem, vs. a guideline of 100 rem, and the dose to an MOI would be 0.49 rem, vs. a guideline of 5 to 25 rem. And as discussed under " Increasing Safety ," the probability and consequences of a DBA can be reduced in many ways. Accordingly, Option 10 focuses on how RLUOB might be used for AC/MC in support of pit production if Congress were to waive the limit of 38.6 g Pu-239E (26 g WGPu) for RLUOB.
While the option has not been studied, it appears, as noted under Option 9, that a MAR limit of 1,000 g WGPu would be enough for RLUOB to perform the AC needed to support 80 ppy, as well as some MC tasks, though more floor space might be needed. Appendix F shows the space breakout for AC under several plans. CMRR-NF would have had about 22,500 sf of lab space. Of that, 9,750 sf would have been used for AC. Another 6,750 sf in RLUOB would have been used for AC. The current plan, with the 26 g WGPu limit, is to use 10,500 sf in RLUOB and 5,600 sf in PF-4 for AC. However, most AC work is less efficient if done in PF-4 than in RLUOB because PF-4 uses gloveboxes and because PF-4, which is SC-I, requires particularly rigorous security measures. If RLUOB could hold 1,000 g WGPu, 15,000 sf could be used for AC, 3,500 sf for MC, with the remaining 1,000 sf available for support activities. PF-4 could use 2,400 sf for sample preparation, which uses a large amount of plutonium and is done in a small lab room already set up for this purpose in PF-4.
Option 10 may merit further study because, if it proves feasible, it would offer advantages that address concerns Congress has raised for many years. Option 7 (AC at LLNL or SRS) would offer some of these advantages as well.
1. Option 10 would reduce cancellation risk. The history of pit production efforts includes cases where decisions by Congress or the Administration have halted a major plutonium building after planning had started but before construction had begun. Conducting pit production support tasks in a building that already exists would reduce this risk. 2. Option 10 would greatly reduce the risk of a plutonium building being built, found unsuitable, and torn down. As described in " Two Other Failed Attempts ," this situation occurred with Building 371 at Rocky Flats Plant and the Nuclear Material Storage Facility at LANL. 3. Using RLUOB would reduce the risk of large cost growth. Congress is concerned about NNSA's record of cost growth in its nuclear facility construction projects, which may be why Congress, in the FY2013 National Defense Authorization Act, P.L. 112-239 , Section 3114, capped spending for UPF and CMRR-NF, and why Section 3112 of P.L. 113-66 , FY2014 National Defense Authorization Act, established a Director for Cost Estimating and Program Evaluation in NNSA. RLUOB has much lab space, and procuring added equipment would not add to the marginal cost if such equipment would be procured for another nuclear facility. Converting more space in RLUOB, strengthening it, or making other changes to reduce risk and increase efficiency would probably not cost as much as a new facility. 4. Equipping RLUOB for AC and some MC would be the fastest way to augment capacity. RLUOB has an infrastructure to support work on small samples, some lab space is already equipped, and empty lab space could be equipped. The capacity should be available before it is needed, providing time to work out process kinks. In contrast, adding equipment to PF-4 would be difficult, costly, and time-consuming because changes to PF-4, an HC-2 building, must comply with many requirements and workers must undergo security checks, and space may not be available. Minimizing the risk of delay is also of value because delay typically increases cost and could disrupt the schedule for weapons work. 5. Section 3114 of the FY2013 National Defense Authorization Act, P.L. 112-239 , requires the Secretary of Energy to construct a building to replace the functions of CMR at a cost not to exceed $3.7 billion. If RLUOB could replace the functions of CMR while avoiding the need to build CMRR-NF, it would save the cost of the latter facility, which NNSA estimated at between $3.7 billion and $5.9 billion in its FY2012 budget request. The savings could be higher. A five-year deferral, NNSA estimates, would add two years to the time to complete CMRR-NF, and delay typically adds cost. CMRR-NF might be canceled in favor of a modular strategy, which Section 3117 of the FY2014 National Defense Authorization Act authorizes. The two modules referenced in Section 3117 would presumably be less costly than CMRR-NF, especially as they would be between 3,000 sf and 5,000 sf, vs. 22,500 sf for CMRR-NF. However, modules would be HC-2 and at least SC-II. As such, the cost of two modules could reach the billions of dollars. 6. Using RLUOB would avoid or minimize design and construction risks, such as design errors. These risks are different than cost and schedule risks, though they may lead to such risks. A case in point from 2013 occurred with UPF. According to the Senate Appropriations Committee, "Most recently, a space fit issue that required raising the roof of the building by 13 feet to fit critical equipment resulted in more than $500,000,000 in additional costs to U.S. taxpayers." 7. As Appendix E shows, RLUOB is much more seismically resilient than CMR. Option 10 could permit NNSA to halt work in CMR by 2019. It might even permit halting this work before then, reducing the time in which CMR poses a safety hazard to its workers and the public. If no other facility is in place by 2019 for AC and some MC, it might be necessary to extend CMR's service life beyond then. However, there is no assurance that that could be done, which would make it harder to meet the 2021 pit production goal. As a cautionary example, the redesign of UPF might push completion of that facility past the date when Building 9212 can no longer be kept in service. 8. Option 10 could make 1,200 sf of lab space available in PF-4 by enabling the gas gun (see Figure 12 ) to be moved out. The target is typically 20-25 g of WGPu. With a MAR limit of 26 g WGPu for RLUOB, the target would take up so much MAR that much other plutonium work in RLUOB would have to be stop and the material containerized when a gas gun experiment was in progress. A MAR limit of 1,000 g of WGPu would avoid that problem. 9. Option 10 would increase efficiency in other ways. For example, PF-4 houses a highly sensitive spectrometer that had to be placed near an outside wall to minimize vibrations. The only suitable space available was in the middle of a room filled with gloveboxes. Moving it to RLUOB would remove clutter from the room. At the same time, it would be easier to use the instrument in a laboratory room outfitted to accommodate it. 10. NNSA anticipates that upgrades will enable PF-4 to remain in service until 2039. Based on experience with other plutonium buildings, RLUOB, which was completed in 2009, should have at least a 50-year service life. If PF-4 and RLUOB can remain in service for another quarter-century, Congress may be able to defer decisions on other plutonium facilities for at least a decade, and defer substantial expenditures on such facilities longer than that. 11. Even if NNSA ultimately moves high-MAR activities from PF-4 to modules, as discussed in Option 12, it would still be desirable if not necessary to use RLUOB for AC to support production of 80 ppy because RLUOB, unlike PF-4 or the modules, is well suited for low-MAR work that uses a substantial amount of floor space. Thus upgrading RLUOB would likely be a component of the module plan, in which case any difficulties attendant upon upgrading RLUOB would be present under the module plan. 12. Placing the pit program on a fiscally and politically sustainable path soon would avoid years of uncertainty for the entire plutonium program, providing a long-term foundation for the rest of the program. That would help NNSA plan that program, other facilities, disposition of excess nuclear material, and budgets. 13. Upgrading existing buildings, rather than building new buildings or transporting material to other sites as part of pit production, should minimize environmental impact. As a result, compliance with NEPA should be simpler and an EIS prepared to comply with the spirit as well as the letter of that law should be less vulnerable to a successful legal challenge.
At the same time, there are several concerns about this option.
1. RLUOB might collapse in an earthquake. The building was designed to have a 50% chance of surviving the 1995 design basis earthquake (DBE), but the 2009 DBE is more powerful. The lowest two floors of RLUOB (basement, utilities; and first floor, laboratory) are built of thick reinforced concrete, and the second floor (lowest office floor) has thick concrete columns; all are seismically robust. The upper two office floors are designed to the structural requirements of an emergency response building, like a hospital or fire station. While the upper two floors are less robust than the lower floors, they are much sturdier than a standard office building, and its seismic robustness could be increased through several methods discussed in " Increasing Safety ." (The "utility" component of RLUOB is the Central Utility Building, separated from RLUOB by about a foot.) It appears that detailed analysis would be needed to determine the seismic performance of RLUOB as is, whether a collapse of the office would breach the laboratory ceiling, what reinforcements would be suitable, how effective they would be, and what they would cost. 2. Non-governmental organizations and members of the public might be concerned about any efforts to relax standards pertaining to nuclear facilities. Safety and other standards exist for a reason; would relaxing them add risk, and if so, by how much? Some might oppose introducing more than 26 g of WGPu into RLUOB on grounds that so doing could pose a direct threat to the surrounding area in the event of an earthquake that collapsed the building. 3. Relaxing standards for one building could set a precedent for so doing for other nuclear weapons buildings or other projects more generally. 4. Some might fear that this project could open the way for other plutonium projects at Los Alamos. As discussed in Option 12, the laboratory is considering a modular option, with a tunnel built to connect PF-4 and RLUOB and reinforced-concrete underground rooms or "modules" built off the tunnel for high-MAR plutonium operations. In this view, using trucks to transport samples between PF-4 and RLUOB would forestall or delay the modular option. Others might favor the tunnel in part because it would facilitate the modular option. 5. Some may fear that NNSA might not do an adequate EIS. One of the tests for a Categorical Exclusion in DOE regulations (10 CFR 1021.410) is
(3) The proposal has not been segmented to meet the definition of a categorical exclusion. Segmentation can occur when a proposal is broken down into small parts in order to avoid the appearance of significance of the total action. The scope of a proposal must include the consideration of connected and cumulative actions, that is, the proposal is not connected to other actions with potentially significant impacts (40 CFR 1508.25(a)(1)), is not related to other actions with individually insignificant but cumulatively significant impacts (40 CFR 1508.27(b)(7)), and is not precluded by 40 CFR 1506.1 or § 1021.211 of this part concerning limitations on actions during EIS preparation.
Similarly, CEQ regulations (40 CFR 1508.7) define "cumulative impact" as follows:
"Cumulative impact" is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.
An EIS does not meet regulatory requirements if it avoids considering all reasonable alternatives, or if only a segment of a proposed action is analyzed, or if the cumulative impacts of multiple actions are not taken into account. "Up-equipping" RLUOB (adding equipment so it can handle more AC/MC to support pit production), building a tunnel to connect RLUOB and PF-4, building one module, building a second module, and building additional modules could easily be segmented. While the modules would be HC-2, and thus significant by themselves, up-equipping RLUOB and building a tunnel to connect it to PF-4 might be seen as "small" actions that would not appear significant. But the cumulative impact of those small actions plus modules would be much larger than just an up-equipped RLUOB plus a tunnel. Further, since there is a possibility of building modules given that the FY2014 National Defense Authorization Act authorized NNSA to spend funds on a modular building strategy, once certain conditions have been met, the EIS would need to analyze the impact of that alternative, including the entire suite of projects involved (such as the tunnel), before committing to any of them. 6. RLUOB, as currently planned, would dedicate a substantial amount of laboratory space to unclassified research on plutonium. This research could explore such areas as basic properties, nuclear forensics, nuclear power plants, and Pu-238. The space would be open to individuals without clearances. Providing space for postdoctoral fellows to conduct plutonium research would benefit LANL by attracting potential recruits to the lab, and discoveries made by these individuals or foreign nationals could benefit the weapons program. If RLUOB is permitted to have 1,000 g of WGPu in order to support the weapons program, most if not all of the unclassified laboratory space would be converted to classified space.
Since the laboratory space at RLUOB could perform AC and some MC work, but questions remain about seismic robustness in light of the possible collapse of the office floors, would it be possible to …
section_title: Option 11. Build a Copy of RLUOB Minus the Office, with Regulatory Relief, for Analytical Chemistry, with PF-4 Conducting the Balance of Pit Work
paragraphs: A concern with RLUOB, even with regulatory relief, is that the office component could collapse in an earthquake and breach the ceiling of the laboratory, releasing plutonium. A simple way to avoid that problem would be to build an "RLB," or Radiological Laboratory Building. Construction of RLUOB was completed in FY2010. The FY2012 NNSA budget request shows the total project cost of the facility as $164.0 million, including the office floors and the Central Utility Building (CUB), and another $199.4 million for installing equipment. An RLB built as a copy of the laboratory space in RLUOB should cost considerably less (when adjusted for inflation) than RLUOB because the office structure would be eliminated, the plans for the lab space already exist, and lessons learned from RLUOB could be applied to facilitate construction. The CUB was intended to provide utilities to CMRR-NF, a larger building than RLUOB, as well as to RLUOB; CUB should thus have the capacity to support most of RLB's needs. If RLB were built as a copy of the basement and laboratory floor of RLUOB, it would need regulatory relief in order to hold enough plutonium to do the AC/MC work needed to support 80 ppy.
Regulatory relief would be unnecessary if RLB were to be built as an HC-3 building. However, meeting HC-3 standards would result in a substantial cost increase for paperwork, studies, and testing to certify the same equipment (fans, filters, fire suppression equipment, etc.) because the standards would be much higher. Another issue for RLB is that that structure would probably be sited in the location previously planned for CMRR-NF. In that case, building it there could preclude modules. Some would see that as a plus, others as a minus.
If regulatory relief for RLB were not forthcoming, or if an HC-3 RLB proved too costly for a building holding 1 kg of WGPu, or if RLB plus PF-4 did not provide enough space or MAR for all the pit work that would be needed to produce 80 ppy, another approach would be to …
section_title: Option 12. Build Modules Connected to PF-4 for High-MAR Plutonium Work
paragraphs: Los Alamos's preferred approach to the plutonium strategy is a three-part plan: maximize use of RLUOB, repurpose space in PF-4, and build modules linked to PF-4. This section discusses the modules and their pros and cons.
In concept, the modules would be like "RLB" in that they would be seismically reinforced laboratory-only space. There would be key differences: the modules would be completely buried instead of mostly aboveground, would be designed and built as HC-2, would do high-MAR work instead of AC/MC, and each would be for a single purpose.
PF-4 is built as modules under one roof. They all utilize the infrastructure and supporting systems of PF-4, such as shipping, receiving, waste management, nondestructive assay, entry control, and security, but are designed so plutonium accidentally released in one room would be contained within that room. The LANL approach envisions building a tunnel from PF-4 to RLUOB with modules connected to the tunnel. The first modules would be for tasks involving large amounts of MAR: Pu-238 processing, a pit foundry, or processing plutonium dissolved in acid. Moving these tasks out of PF-4 would remove about 70% of the MAR in PF-4. So doing would make more MAR available for other tasks involving MAR while staying within the limit prescribed for PF-4.
A key lesson learned from seismic simulation studies of PF-4 and RLUOB is that the larger the dimensions of the structure, the greater the seismic loads imparted to equipment anchored to the floor. As currently envisioned, modules, at 3,000 to 5,000 square feet, would be smaller than RLUOB (19,500 sf) and PF-4 (60,000 sf). They would be lower in height and narrower than those buildings and made of thick concrete heavily reinforced with rebar. They would be constructed in the 3-acre excavated area between RLUOB and PF-4 that was dug out for CMRR-NF (see Figure 4 ) and then buried with a special concrete that matches the density of the rock (called tuff) on which the modules would sit. By matching the density of the tuff, a seismic wave would pass through the concrete more smoothly, reducing its impact on the modules. Surrounding the structure with concrete would reinforce the walls. A buried structure has the added advantages of minimizing concerns regarding securely transporting plutonium between the modules, PF-4, and RLUOB, and avoiding such natural phenomena as fires and high winds.
Los Alamos recognizes that the "big box" approach—building a single large building like PF-4 or CMRR-NF—no longer appears politically and fiscally sustainable over the decades required to plan and build such a facility. As Senator Lamar Alexander said, "if the NNSA does not find a more effective [way] to deal with design of these large multi-billion dollar facilities that NNSA builds it's going to lose congressional support for those facilities." Part of the problem is that a big box design is typically too ambitious and too cautious at the same time. It is too ambitious because when there is an opportunity to build a plutonium facility only once in 25 or 50 years, there is a tendency for the design to include everything that might possibly be needed over the building's life. It is too cautious because it must comply with a vast and growing body of regulations, often of increasing specificity. Meeting goals and requirements simultaneously is difficult, a difficulty compounded because uncertainties concerning goals and requirements increase the further out projections are made.
Accordingly, in this view, a new approach is needed. Los Alamos argues that modular construction offers numerous advantages. Since modules would be much smaller than large buildings, they could be built faster and at lower cost. Since each module would house a single operation, safety planning could be specific to each module instead of, as at present, accommodating the highest-risk type and quantity of material. Modules could be built as needed, rather than having to incorporate in a single building all the functions that it might need to perform at some point during its service life. The modular approach, it is argued, would permit a steady level of funding rather than the large spikes of funding involved with construction of a large building like CMRR-NF, making the funding profile more predictable for Congress and the Administration. Design and construction of each module would benefit from lessons learned from previous modules, reducing cost. Reducing MAR in PF-4 would extend that building's service life if future regulations were to reduce its permitted MAR, as was the case with CMR.
While the modular building strategy is, at this point, only a concept, it is gathering steam. Preliminary design work, cost estimates, and schedule estimates are underway and, as noted, the FY2014 National Defense Authorization Act authorizes this strategy. Nonetheless, several questions bear on its desirability:
Is it needed? Could PF-4 plus RLUOB with regulatory relief produce 80 ppy and perform other plutonium tasks without the modules at acceptable risk levels? Would moving Pu-238 work to INL or SRS obviate the need for modules? Pu-238 accounts for 40% of MAR permitted for PF-4, and 8,000 sf of lab space. Would moving it out free enough MAR and space for PF-4, especially in conjunction with RLUOB, to do the added pit work needed to reach 80 ppy? Is there a need to move 70% of the MAR out of PF-4? Is it needed now? Future requirements for plutonium work might require added space. But NNSA projects that the TA-55 Reinvestment Project will extend the service life of PF-4 to 2039, for a total of 61 years, a projection not contingent on building modules. If RLUOB has a 50-year service life, it could remain operational until 2059. Can a decision on modules be delayed? While modules might save money by drawing on PF-4 infrastructure, they would be HC-2 buildings. As such, they would need their own ventilation, continuous power, fire suppression equipment, emergency access, and the like, all of which would be safety class and thus very expensive. What would the modules cost? NNSA has experienced delays and cost growth in many of its larger nuclear construction projects. The modular approach offers features that could help avoid these problems, such as a smaller scale, application of lessons learned from building previous modules, and construction of each module to accommodate only the purpose for which it is built. But the modules would be separate new facilities. Given NNSA's track record, can Congress have confidence that the modules would not encounter cost and schedule problems? Two arguments for modules are that they would make the funding profile more predictable and that modules could be built as needed. But if the schedule for module construction cannot be predicted, neither can the funding profile. Compared to modules, would it be faster and less costly to upgrade PF-4, use RLUOB for AC, and move Pu-238 out of PF-4? MAR limits in PF-4 are conservatively set. Mitigation measures, discussed next, would further increase the difference between the frequency of the DBE and the frequency of an accident resulting from that earthquake. Could MAR limits be raised without serious adverse potential consequences? Would that reduce the need to build modules as a way of reducing MAR in PF-4?
section_title: Making RLUOB/PF-4 Options Safer and More Efficient
paragraphs: Safety and efficiency are not static. Both can be improved. "Improved safety," as used here, means reducing the risk of a design basis accident (DBA). (Other types of safety, such as reducing the number of falls, are dealt with on a routine basis and are not considered here.) "Improved efficiency," as used here, means increasing capacity (number of ppy). This analysis focuses on Option 10, as this analysis is most applicable to that option; the analysis would also apply to Options 8, 9, and 11. Regarding Option 1, work is already underway on improved safety through TRP. Improving safety and efficiency are not relevant to Options 2, 3, 4, and 12 because, as new buildings, they would be designed and built to comply with the most modern safety standards. Improving safety and efficiency to a significant degree is not practical for Option 5 because CMR is so vulnerable to an earthquake. This analysis is also not relevant to Options 6 and 7, which involve modifying existing buildings at sites other than LANL.
subsections: section_title: Increasing Safety
paragraphs: How could the risk of a DBA be minimized? A DBA must be prepared for buildings that are HC-3 and higher, not Radiological Facilities. However, if RLUOB held 1 kg of WGPu, whether as an HC-3 building or a Radiological Facility with modifications and regulatory relief, it would be beneficial to construct a DBA in order to analyze the sequence of events leading to the DBA. The key point is that the DBA sequence is not inevitable; a DBA would show many points at which the accident sequence could be interrupted. Taking actions to interrupt that sequence would greatly reduce the probability that the entire DBA sequence would occur, thereby reducing the likelihood that anyone would receive any dose and reducing the dose should the DBA occur.
PF-4, as an HC-2 building, has a DBA. NNSA is conducting work at PF-4 through TRP to reduce the probability and consequences of a DBA. A DBA for RLUOB might specify an amount of Pu-239E in the building and include the following sequence: an earthquake that collapsed the building, followed by a fire that converted plutonium at risk to plutonium oxide particles that the fire lofted into the air, resulting in a dose to personnel beyond DOE guidelines. This section discusses possible ways to mitigate the risk of each event in the DBA sequence.
subsections: section_title: Reducing the Risk of Building Collapse
paragraphs: LANL did not study the probability that RLUOB could survive an earthquake of given magnitude because that analysis is not required for a Radiological Facility. However, as discussed in Appendix E , RLUOB was designed to survive the 1995 design basis earthquake, which was appropriate for an HC-3 building. Since then, the DBE has been increased in severity. If RLUOB is to be used for 1,000 g of WGPu, whether upgraded to an HC-3 building or not, it may prove desirable to strengthen it. This could be done in several ways; note that these measures could reduce the consequences as well as probability of building collapse.
The Stanford Linear Accelerator Center (SLAC) in California has facilities built near the San Andreas Fault, so seismic resistance is a design consideration. Matthew Wrona, Director of the Facilities Division at SLAC, noted that most buildings typically are designed to resist vertical loads, as they must bear the gravity loads. An earthquake, however, imposes lateral (horizontal) loads as well as vertical loads, and seismic resistance requires resistance to both. Wrona pointed to several methods to strengthen an existing building to resist seismic loads:
Strengthen connections between columns and (horizontal) beams, such as by using welded moment resisting connections, to increase lateral load resistance of the building. Install diagonal bracing in load bearing exterior and interior walls. Add steel plates to the inside or outside of a building to stiffen it against lateral loads. Use buttresses anchored to the ground and to the outside of the building. Buttresses would resist lateral loads. Strengthen floor diaphragms to distribute lateral loads to supporting walls. 
SLAC has used several of these techniques to brace office buildings, as Figure 13 shows.
As Figure 14 shows, buttresses have been used for many centuries to support buildings. Another strengthening method is base isolation technology, as shown in Figure 15 .
A LANL structural engineer provided the following comment:
Any number of techniques could be used to strengthen RLUOB to resist higher seismic forces. External bracing could be used, and the use of this technique at SLAC is a good example. Other possibilities may be to strengthen the internal steel-to-steel connections or the installation of internal shear walls and/or bracing. Base isolation has been applied to some structures to reduce the seismic loads that they would see during an earthquake. It might be applicable to RLUOB, either at the building foundation or at the junction between the concrete structure and the steel office structure above it. Another option may be to install internal dampers that absorb the energy of seismic motion that reduce structure displacements and accelerations which lead to reduced seismic loads. The point is that there are effective upgrades that could be implemented to improve seismic resistance. To choose the most effective set of upgrades, seismic/structural engineers need to complete a thorough analysis of the existing facility with an understanding of the performance required and using the appropriate ground motion in conjunction with applicable federal, state, and local seismic codes.
NNSA has undertaken several projects to reduce the risk of building collapse for PF-4. Its TRP is intended to add about 25 years of expected useful life. TRP has multiple projects, including seismic upgrades to glovebox stands, as shown in Figure 16 . This upgrade is intended to prevent the gloveboxes from falling over during an earthquake and releasing plutonium. NNSA undertook many other projects in conjunction with its June 2011 Seismic Justification for Continued Operation. It noted that repairing one building feature (drag strut) reduced the dose from 2,100 rem for a once in 5,000 year event to 143 to 278 rem for a once in 2,000 year event. NNSA took many other actions to address seismic hazards, including "strengthen[ing] the roof, thereby addressing the most significant known weakness—a building collapse failure mode," and "brac[ing] ventilation room columns, addressing the next most significant known weakness." Additional repairs, NNSA estimated, could reduce the dose to an MOI to less than 25 rem. 
section_title: Reducing the Risk of Fire
paragraphs: A second part of the DBA is that building collapse is followed by a fire that engulfs several rooms of the laboratory space. Various methods could be used. The simplest is to reduce the amount of combustible material in the building. While this seems self-evident, Los Alamos removed about 20 tons of combustible material from PF-4 between 2010 and 2012. Other steps taken in PF-4 included implementing a program to control ignition sources, repairing the main fire wall, addressing other structural issues, and increasing the capability of fire suppression systems. NNSA calculated that these and other measures to reduce the consequences of a post-earthquake fire at PF-4 would reduce the dose from this accident from 2,860 rem as of December 2008 to 23 rem as of June 2012 and well under 1 rem by September 2020. (This dose is for an MOI.) Similar measures should reduce the risk of a fire in RLUOB.
section_title: Reducing the Amount of Plutonium Consumed in a Fire
paragraphs: A fire would not loft a plutonium ingot into the air because plutonium melts at a high temperature, 1,183 degrees F, and a fire would likely form a layer of plutonium oxide on the surface of the ingot that would keep oxygen from reaching the interior. To be lofted into the air in a form in which it can disperse and be inhaled, it must be converted to tiny (respirable) particles of plutonium oxide. Such particles can be formed if a fire reaches molten plutonium, plutonium shavings, or plutonium dissolved in acid; the latter would readily combine with oxygen if the acid boiled away.
NNSA has taken many steps to reduce the amount of plutonium consumed in a fire in PF-4. These include installation and use of fire-resistant safes and containers for storing nuclear material, procurement of containers for special nuclear materials that "are designed to provide increased assurance of confinement in a seismically initiated fire when stored in environments not susceptible to direct flame impingement," "replac[ing] vault sprinkler heads with lower-actuation-temperature heads that will respond sooner and limit the development of a vault fire," and "impos[ing] restrictive material-at-risk limits to reduce the amount of plutonium that could be released in an accident." Another step is making sturdier gloveboxes and anchoring them more strongly to the floor so as to reduce the risk that they would topple over in an earthquake, releasing plutonium. Figure 16 shows the progressive strengthening of gloveboxes. Future plans include installation of fire suppression equipment in gloveboxes and improving fire barriers.
There are many potential ways to reduce MAR—actually, MAR per pit—that would reduce the amount of plutonium that a fire in RLUOB would consume. Since many AC techniques date back to the Cold War, it may be possible to update them to take advantage of current technologies and requirements in order to reduce MAR. Possibilities include:
Take fewer samples per pit. AC at present is performed much as it has been since the Cold War, as discussed in " The Pit Production Process ." Improved analytic instruments and improved understanding of plutonium and its impurities might permit reducing the number of samples. It may also be the case that these numbers reflect an excess of caution and an abundance of resources characteristic of the nuclear weapons program during the Cold War. Taking fewer samples per pit would reduce the sample prep workload in PF-4, the AC workload in RLUOB, and the workforce and floor space required in both buildings. Perform fewer analyses per sample. Sometimes multiple analyses are performed to reduce the risk of missing needed information in process control. Reducing redundant analyses should have similar benefits as reducing the number of samples per pit. Accept less precision of measurement. While an AC procedure that originated decades ago might require precision to within plus or minus 1%, precision to within plus or minus 5% or 10% might suffice. That could permit faster sample processing, reducing MAR per pit. In addition, relaxing the requirement would, in some cases, permit one analysis technique to perform several types of measurements, while more precise techniques might require a piece of equipment for each measurement type. Using fewer pieces of equipment would also free up floor space in PF-4 or RLUOB. Devise ways to reduce the time that various AC techniques require. Faster processing would reduce the number of hours that material is at risk for each pit, and would permit more work to be done in a given amount of floor space, perhaps with fewer workers, reducing aggregate worker exposure to radiation. By reducing MAR per pit, RLUOB could support AC for a higher production rate, or could conduct AC for a given number of pits under a lower MAR ceiling.
section_title: Minimizing the Amount of Plutonium Oxide Lofted into the Air
paragraphs: Even if an earthquake collapsed the building and a fire converted some plutonium to plutonium oxide particles, that material would not pose a threat unless it escaped from the building and was lofted into the air by the fire. Not all the plutonium at risk in RLUOB would leak into the atmosphere. The first floor of the building is laboratory space, but there is a basement below it and three floors above it. In an earthquake that collapsed the entire building, the first floor would collapse into the basement and the upper floors would collapse onto the laboratory space, sealing in some plutonium. Other steps might further reduce leakage. As a possible example, the foam used to extinguish aircraft fires, if used in a fire in RLUOB, might trap plutonium. A careful analysis of such techniques would be required to determine their efficacy and whether they would create criticality problems. Development of such techniques would be of value for RLUOB, PF-4, and other buildings containing nuclear materials.
section_title: Dose Would Be Very Low Even Without Mitigation
paragraphs: Even in a worst-case accident, the dose from plutonium released from RLUOB would be very low. NNSA, in discussing PF-4 stated, "Unmitigated/mitigated radiation doses were 7,250 rem/2,900 rem, based on an accident scenario involving 5MT [metric tons, i.e., 5,000 kg] of one plutonium material form [molten WGPu], an unconstrained full-floor fire, and an assumed 40 percent leak path factor [i.e., 40 percent of plutonium is released into the air]." (That calculation is beyond worst case, as the MAR allowance for the PF-4 main floor is 2,600 kg Pu-239E. Nonetheless, it is useful for providing a baseline for calculating the dose that might result from the release of 1 kg of WGPu.) If RLUOB held 1 kg of WGPu, and if the leak path factor for this accident at RLUOB, without mitigation, were 40%, then the resulting dose would be 1/5,000 th of 7,250 rem, or 1.45 rem. Even if the leak path factor were 100%, the dose would be 3.6 rem, near the bottom end of the dose range having no detectable clinical effects. (It is unclear if this dose is for MOI, CW, or others.) Appendix B presents another, more detailed calculation that produces even lower results for an MOI. Further, that Appendix shows that the value of "airborne release fraction" is very conservative, so that the dose could be tens or even 100 times less than shown in Table B-1 and Table B-2 .
section_title: Increasing Efficiency
paragraphs: Efficiency, in this context, refers to the efficient use of space so as to enable more pit work to be performed in PF-4 and RLUOB.
subsections: section_title: Increasing Space for Pit Production and Supporting Tasks
paragraphs: Producing 80 ppy would require more space for production equipment and AC. (Los Alamos has not calculated the precise amount of space required, and the requirement could change between now and 2030, when the capacity is needed.) Since pit fabrication could only be done in PF-4, more space in that building would have to be dedicated to that task. Some ways of achieving this space are straightforward:
RLUOB could be utilized for AC and some MC. MC would not require much more space to support 80 rather than 30 ppy, as it is used to qualify production equipment and processes and to help solve production problems. However, some MC, such as the gas gun, might be moved into RLUOB. Some space could be repurposed; other space could be made available by moving Pu-238 out of PF-4.
section_title: Increasing Efficient Utilization of Space
paragraphs: Space in PF-4 could be utilized more efficiently, which would have the same effect as increasing floor space.
PF-4 and RLUOB could operate on two shifts per day. This would be much less costly, much more feasible, and much quicker than building new plutonium buildings, and would have much less environmental impact. LANL estimates that using two shifts per day rather than one increases productivity by a factor of 1.6. Multiple shifts are not new to the nuclear weapons complex; Rocky Flats Plant sometimes operated with three shifts a day, and SRS currently conducts some operations that way. As noted earlier, the vault in PF-4 for holding plutonium is being cleaned out, with excess material sent to WIPP for final disposition. Excess material that may need to be retrieved could be sent to other sites. It may be possible to design equipment to minimize space requirements. Space efficiency was not a major consideration when PF-4 equipment was originally designed; focusing on this goal and bringing modern technology to bear might permit more work to be done in a given space. Having more plutonium in a room would increase the dose to workers unless shielding is increased; this would be a much greater concern in PF-4, where work with kilogram quantities of plutonium is conducted, than in RLUOB, which would use very small samples.
section_title: Gathering Information on Various Options
paragraphs: In order to examine the costs, risks, and benefits of the options discussed in this report, Congress would need further information. To gather it, Congress could direct NNSA to conduct several studies, including the following:
Study of potential PF-4/RLUOB production capacity: Since it is unlikely that new plutonium buildings (especially large ones) will be built for many years, PF-4 and RLUOB have value beyond their cost. Many measures could increase capacity, such as moving Pu-238 out of PF-4, repurposing space in PF-4, and permitting RLUOB to perform all AC. Congress could direct NNSA to study whether some combination of such measures would enable production of 80 ppy while maintaining other essential plutonium missions in PF-4, and the number of ppy RLUOB and PF-4 could produce if more or less than 80.
Study of repurposing PF-4 space: Los Alamos plans to repurpose some space in PF-4. Could enough space be made available for pit production and support without disrupting other critical missions in the building? If such disruption was required for pit production, could other missions be done in existing facilities elsewhere in the nuclear weapons complex, or would new facilities have to be built? If new facilities were required, what would they cost and how long would they take to build, and what would happen to the mission before they were completed?
Study of the feasibility and cost of converting RLUOB to HC-3: RLUOB was built but not certified to HC-3 standards; it is sometimes called an "HC-3-like" building. In order to hold 1,000 g of WGPu while complying with regulations, it would have to be certified to HC-3. This would involve many actions. Many would be studies, but some of them could lead to physical changes to the building, such as seismic bracing or installation of equipment. It is not clear what physical work would be required. A "study of studies" would help determine if conversion would be feasible, and if so at what cost.
Study of adverse consequences of allowing RL U OB to operate as is but with 1,000 g WGPu: Converting a Radiological Facility to HC-3 would entail costs, yet the dose resulting from an earthquake that collapsed RLUOB would be far below the guidelines set by DOE, as Appendix B shows. Congress could direct an independent organization to study the adverse consequences of using RLUOB for 1,000 g of WGPu as is, that is, with AC equipment installed but no steps to convert the building to HC-3. If it is determined that RLUOB as is would not provide adequate safety with 1,000 g WGPu, a related study could examine if there are additional steps short of full conversion to HC-3 that would provide adequate safety, and what they would cost.
Study of having LLNL, SRS , or both perform some AC to support pit production : LLNL and SRS have infrastructure to perform AC to support pit production, though beyond some level of capacity they would need to upgrade equipment and hire additional staff. There would be benefit from dispersing AC expertise, capacity, and work to other sites in the nuclear weapons complex, but also benefit from concentrating them at LANL, the plutonium center of the nuclear weapons complex. It seems unlikely that a site other than LANL would perform all AC to support pit production. At issue: Should one or more sites other than LANL perform some AC to support pit production? If so, how much capacity should be dispersed to other sites? Which site or sites should be chosen? What would it cost to upgrade the site or sites for that capacity? 
Study of Pu-238 options: Pu-238 activities are costly given the high level of radioactivity of that material. Pu-238 work could be moved to INL, SRS, a module at LANL, or perhaps other sites. DOE's Office of Nuclear Energy prepared a study on this topic. However, that study did not consider the costs and benefits to the weapons program of moving Pu-238 out of PF-4; those costs and benefits might change the calculus of that move. Specifically, if moving Pu-238 to another site made a major contribution toward permitting production of 80 ppy without building new buildings, the value to the weapons program would be significant, and reducing MAR in PF-4 could help extend its service life. On the other hand, while DOE has estimated the cost of the INL or SRS options for Pu-238 to be several hundred million dollars, other costs would be involved, as well as temporary disruption of the Pu-238 program. Congress could direct NNSA to contract with an independent organization to study these costs and benefits.
Study of cost implications of the regulatory system: A Radiological Facility is able to hold 38.6 g Pu-239E (26 g WGPu). As shown by RLUOB, such facilities can be affordable and can be built. In contrast, the history of the past quarter-century, as discussed in " A Sisyphean History: Failed Efforts to Construct a Building to Restore Pit Production ," has been that a facility intended to hold more than 26 g WGPu has seen cost and schedule escalate to the point where it cannot be acquired. These efforts have resulted in the expenditure of billions of dollars with the net result of canceled programs, unusable buildings that had to be demolished, and continued operations in "decrepit" facilities. Congress could task NNSA to report on cost implications of the current regulatory system governing nuclear facilities, focusing on tradeoffs between cost and risk.
section_title: Concluding Observations
paragraphs: Long-term planning is difficult for all parties concerned . Delays and cost growth by NNSA on its major facilities reduce confidence in NNSA's cost and schedule projections, making it difficult for Congress and the Administration to budget for these facilities. NNSA sources say that congressional budgeting outside the regular budget process, such as sequesters and short-term continuing resolutions, and withdrawal of congressional support, such as the termination of MPF, make it difficult for NNSA to plan. Changes in Administration planning, such as the deferral of CMRR-NF, make it difficult for Congress and NNSA to plan.
Long-term planning for pit production has proven particularly difficult . NNSA provides plans going out 10 to 20 years. However, these plans have often been stretched out, canceled, or modified substantially. Pit production at Rocky Flats Plant halted in 1989, yet LANL did not produce its first war reserve pits until 2007, NNSA has not needed to expand its small capacity, and there is still no plan for larger-scale pit production. Planning for MPF began in 2002, and Congress canceled it in 2005, followed by planning for CMRR, with the Nuclear Facility deferred "for at least five years" by the Administration in its FY2013 budget request. Similar delays have occurred with other nuclear weapons complex construction projects and with LEPs. While organizations need long-term plans as general guides to future plans, this history raises questions about the value of such planning.
Requirements for pit production capacity have been fluid, reducing their credibility . The options studied for MPF in a 2003 EIS were between 125 and 450 ppy. Even if pits had a service life of 45 years, as was thought at the time, a 450-ppy capacity would support a stockpile of some 20,000 weapons, far more than the stockpile had. Then, the interim capacity at LANL was 10 ppy, with a goal of 30 ppy by 2021 and a requirement of 50-80 ppy by around 2030. Yet this latter requirement was not based on an analysis of weapons, targets, and scenarios, but on what NNSA estimated that Los Alamos could produce with PF-4 and CMRR-NF. Despite the deferral of CMRR-NF, and congressional authorization for NNSA to pursue a modular strategy as an alternative to that facility, the requirement for 50-80 ppy remains, and it is unclear if the number needed is 50 or 80. At the same time, steady increases in estimates of pit life, steady reductions in numbers of weapons, and the possibility of reusing pits from retired weapons may reduce the required capacity. As a consequence, it is hard to know what capacity is needed, and thus what new facilities or modifications to existing ones are needed.
Differing time horizons between Congress and NNSA, and between political and technical imperatives, cause problems . Congress and the Administration, on the one hand, and DOE, NNSA, the labs, and the plants, on the other, work on very different timescales. It takes well over a decade, at best, for NNSA to bring a major nuclear facility project from initial approval to design, construction, and operation. In contrast, Congress and the Administration have changed course often on a plutonium strategy, sometimes from one year to the next. The more time from start to finish of a project, the more chance there is for intervening events to alter plans. Thus it would be to NNSA's advantage to drastically shorten the time from start to finish of a project. A construction cycle of a decade or more (or 24 years and counting in the case of a new plutonium facility) faces great difficulty when its funding hinges on a political cycle of one or a few years.
For a successful plutonium strategy, Congress would find unacceptable management that allows costs to grow immensely, 10-fold in some cases, or that allows multi-year delays. At the same time, Congress and the Administration cannot expect a project to be completed in a couple of years. Analysis of alternatives, site surveys, compliance with NEPA requirements, planning, contracting, and construction typically take years.
Thus, time is of the essence and delay is the enemy. This is a problem for Congress, the Administration, DOD, NNSA, the nuclear weapons complex, and the nation. Is there is a meeting-ground between the political and technical worlds? Can NNSA define the need for a major nuclear facility construction project, then quickly design it, comply with various federal, state, and local regulations, and build it? How could NNSA expedite the process? Can it avoid cost growth, delay, and mission creep? Conversely, once a project is defined, can Congress and the Administration commit to it on a longer-term basis?
NNSA would need to gain the confidence of Congress in its ability to manage major construction projects. The capacity range studied for MPF implied the nominal ability to support a stockpile far larger than the then-current and likely future stockpile. CMRR-NF experienced a several-fold increase in estimated cost and years of schedule slippage. Failing to provide a realistic estimate of required capacity or to stay remotely close to cost and schedule estimates had consequences. Congress canceled MPF, and the Administration proposed to "defer" CMRR-NF for "at least five years." And as noted in " Two Other Failed Attempts ," two plutonium buildings were built, found to be unusable for their intended purpose, and were torn down. Congressional support for a modular strategy—yet another change in plans—increases the likelihood that the deferral of CMRR-NF will be a cancellation. Many believe that NNSA weakens its case for future projects when it releases estimates that are far in excess of a capacity that seems reasonable, or that are far below the ultimate cost and schedule, or when it changes its plans repeatedly.
There are costs and risks to doing nothing . Time spent in planning and construction for new buildings to support pit production can reduce risk, for example by studying the impact of the facility on the environment, by studying the seismicity of the construction site, by designing the facility to meet requirements (such as for Hazard Category 2 or 3), and by incorporating measures in the design to reduce dose that individuals could receive from a major accident. However, if history is a guide, it could take many years before a new facility could become operational. Until then, whether the new facility is at Los Alamos or elsewhere, CMR must be used to provide AC support for pit production in PF-4. This entails multiple risks and costs:
CMR is at high risk of collapse in the event of even a moderate earthquake. Collapse would kill many workers in the building. Pit production requires much more AC than PF-4 can accommodate. Collapse of CMR, without another building to conduct AC, would—not could—disrupt pit production until another facility for AC came on line, which could take years. Bringing another facility online on an emergency basis would probably cost more than doing so in an orderly manner, and shortcuts taken to expedite design, siting, and construction could increase the risk of problems down the road. CMR has a MAR of 9 kg of Pu-239E, and all the plutonium in that facility is considered at risk because no vault or container could be counted on to survive that building's collapse. Dispersal of some of that plutonium could place collocated workers and members of the public at risk. Depending on specifics of the collapse (wind direction, fire, form of plutonium, amount of plutonium escaping, etc.), dispersal of the plutonium could contaminate and force the closure of parts of the laboratory, possibly for months or years. That would disrupt laboratory operations, with operations affected at random based on which areas were contaminated. Cleanup of a large area contaminated by plutonium would be extremely costly and time-consuming. It would be a more effective use of those funds to avoid that problem by moving operations out of CMR as soon as possible.
A facility can be safe without being compliant . As Appendix B shows, if RLUOB had 1 kg of WGPu, all of which was released in a DBA, the accident would result in doses well below DOE guidelines. Yet RLUOB would be in compliance with DOE regulations as a Radiological Facility only if it had less than 26 g of WGPu. As a corollary, there is a tradeoff between cost and regulatory compliance: Where is the point of diminishing returns?
Should plutonium quantity in a building be limited by MAR or dose? The regulatory system defines a building's Hazard Category by MAR. An HC-3 building can hold between 38.6 grams and 2,610 grams of Pu-239E; a Radiological Facility can hold up to 38.6 grams. The objective is safety; however, MAR is a surrogate for safety. It is simple for regulators to measure MAR. In contrast, determining dose to a collocated worker or a maximally-exposed offsite individual requires a complex analysis for each building, taking into account such factors as details of construction, measures taken to increase seismic robustness and fire suppression, and assumptions on the amount of plutonium that would be lofted into the air in an earthquake, wind speed, and wind direction. Yet it is dose, not MAR, that determines whether an individual is safe, and as shown in Appendix B , even with MAR of 2,610 g Pu-239E (1,750 g of WGPu) for RLUOB, the maximum permitted in an HC-3 building, dose to those individuals would be far below DOE guidelines.
Weapons and infrastructure constrain policy and strategy . Logically, these four elements should be linked, and policy and strategy should drive weapons and infrastructure. But given cancellations, multi-year schedule slippages, and major cost growth for LEPs and infrastructure facilities, even if strategy calls for having certain numbers of a certain weapon by a certain year, if an LEP is delayed by cost growth or infrastructure delays, it is the strategy that adapts.
The political system is more flexible than the regulatory system . Regulators are bound by statutes, regulations, orders, and standards, and can only determine if a plan complies with these rules without regard to cost. Standards define acceptable risk: a Radiological Facility must have less than 38.6 grams of Pu-239E; a Security Category IV facility can have up to 200 grams of pure plutonium; the DOE guideline is for an MOI to receive a dose of no more than 25 rem over 2 hours. But this system is inflexible. It does not have a way of trading risk (and the benefit of reducing it) against cost (and the benefit of reducing it). As a result, it may force the expenditure of years, and many millions of dollars, to further minimize an already-minimal risk. In order to inject cost-benefit calculations into recommendations by DNFSB, Section 3202 of H.R. 1960 , the FY2014 defense authorization bill as passed by the House, required DNFSB to provide an analysis of the costs and benefits of its recommendations if requested to do so by the Secretary of Energy; in such instances, the Secretary would also be required to conduct a similar analysis. This provision, however, was not included in the final legislation, P.L. 113-66 .
Even so, while the regulator can present costs and benefits, only the political system has the authority, ability, and culture to decide which tradeoffs are worth making, and to offer regulatory relief. For example, political decisions could make the difference between whether or not a RLUOB/PF-4 option is feasible. If the DOE hazard categorization standard is applied, so that RLUOB could hold only 26 grams of WGPu, then RLUOB could provide very limited AC support for pit production. If it were upgraded, the regulatory system could determine only if the upgrades would meet HC-3 requirements. In contrast, the political system could judge whether certain upgrades would reduce the risk to an MOI enough, with "enough" a matter of political judgment, and if the reduction in risk from these upgrades was worth the cost. The political system could also decide if the risk was acceptable without upgrades.
There are several potential paths forward: Several options discussed in this report have the potential to produce 80 ppy, resolve the Pu-238 issue, and permit other plutonium activities, all at relatively modest cost, in a relatively short time, with no new buildings, and with minimal environmental impact. Determining the cost, schedule, feasibility, and other characteristics of these options would require detailed study.
Appendix A. The Regulatory Structure
Laws
A dense web of "laws" (statutes, regulations, orders, standards, guides, etc.) bears on nuclear facilities and how they are to be built and operated consistent with worker safety, public health, and environmental protection. A critical point is that legislation trumps regulation: since regulations, orders, and standards derive their authority from statutes, statutes can mandate changes in them. Some of the more important laws are:
Atomic Energy Act of 1954, as amended, 42 U.S.C. 2201 et seq., is the fundamental statute setting policy for civilian and military uses of atomic energy and materials. It established the Atomic Energy Commission, which was superseded by the Energy Research and Development Administration and then by the Department of Energy.
Department of Energy Organization Act of 1977, 42 U.S.C. 7101 et seq., established the Department.
National Environmental Policy Act (NEPA) of 1970, 42 U.S.C. 4321-4347, established a national policy on the environment, mandated the preparation of environmental impact statements for certain projects and proposals that could have a significant impact on the environment, and created the Council on Environmental Quality to, among other things, review federal activities to determine their consistency with national environmental policy.
Establishment of Defense Nuclear Facilities Safety Board (DNFSB): 42 U.S.C. 2286 et seq. ( P.L. 100-456 , FY1989 National Defense Authorization Act) established DNFSB as an independent executive branch agency, as described in "Regulators," below. Note that the Nuclear Regulatory Commission does not regulate defense nuclear facilities.
National Nuclear Security Administration Act, 50 U.S.C. 2401 et seq. (Title XXXII of the FY2000 National Defense Authorization Act, P.L. 106-65 ), established NNSA as a separately organized agency within DOE responsible for, among other things, the nuclear weapons program.
Nuclear Safety Management: 10 CFR 830 sets forth requirements that "must be implemented in a manner that provides reasonable assurance of adequate protection of workers, the public, and the environment from adverse consequences, taking into account the work to be performed and the associated hazards." 10 CFR 830 lists its authority as 42 U.S.C. 2201, 42 U.S.C. 7101 et seq., and 50 U.S.C. 2401 et seq.
Nuclear Safety Analysis Report, DOE Order 5480.23, April 30, 1992. Its purpose is "to establish requirements for contractors responsible for the design, construction, operation, decontamination, or decommissioning of nuclear facilities to develop safety analyses that establish and evaluate the adequacy of the safety bases of the facilities. The Nuclear Safety Analysis Report (SAR) required by this Order documents the results of the safety analysis."
Safety Analysis Requirements for Defining Adequate Protection for the Public and Workers, Recommendation 2010-1 issued by DNFSB to the Secretary of Energy, October 29, 2010.
Regulators
The main regulators of nuclear weapons complex facilities are as follows:
The Defense Nuclear Facilities Safety Board (DNFSB ) is an independent executive branch agency. Its mission, as set by legislation, is "to provide independent analysis, advice, and recommendations to the Secretary of Energy to inform the Secretary, in the role of the Secretary as operator and regulator of the defense nuclear facilities of the Department of Energy, in providing adequate protection of public health and safety at such defense nuclear facilities." It is to "review and evaluate the content and implementation of the standards relating to the design, construction, operation, and decommissioning of defense nuclear facilities of the Department of Energy … at each Department of Energy defense nuclear facility. The Board shall recommend to the Secretary of Energy those specific measures that should be adopted to ensure that public health and safety are adequately protected." Recommendations are central to DNFSB's role, especially since that agency does not issue regulations. Recommendations are not requirements, but "To date, the Secretary of Energy has accepted every Board recommendation, though three were accepted with conditions or exceptions described in the Department's acceptance letters."
The DOE Office of Health, Safety and Security (HSS) integrates DOE "Headquarters-level functions for health, safety, environment, and security into one unified office.... HSS is focused on providing the Department with effective and consistent policy development, technical assistance, education and training, complex-wide independent oversight, and enforcement."
The DOE Office of NEPA Policy and Compliance has as its mission "to assure that the Department's proposed actions comply with the requirements of the National Environmental Policy Act (NEPA) and related environmental review requirements … that are necessary prior to project implementation. The Office is the Departmental focal point for NEPA expertise and related activities in all program areas, covering virtually every facet of the Department's diverse and complex operations."
The DOE Office of General Counsel reviews environmental impact statements and similar documents and decides whether to approve their release to the public.
NNSA Headquarters sets policy on the nuclear weapons complex, such as major construction; its programs, such as LEPs; and its operations and maintenance.
NNSA Field Offices are part of the regulatory system. Nuclear weapons complex sites are government-owned, contractor-operated. Field offices hold the contracts with the contractors and interact directly with them. For example, the Los Alamos Field Office handles day-to-day administration of the contract with the contractor, Los Alamos National Security, LLC. NNSA headquarters, in conjunction with Congress and the Administration, sets policy in such matters as how many pits to produce and what facilities to build, and the field office provides direction to the contractor for implementing policy while abiding by rules, such as for safety and security.
Appendix B. Calculation of Dose as a Function of Material At Risk
If Congress were to grant RLUOB regulatory relief so that it could hold 500 g to 1,000 g of WGPu, what risk would that pose to laboratory staff and members of the public? The following equations calculate dose resulting from a major accident that involved these quantities of plutonium, using assumptions as explained below. These calculations are only for dose, and are specific to RLUOB. They do not assess risk to individuals inside the building, nor do they assess risk from fire, earthquake, gas main explosions, and the like.
This table calculates the dose to two types of individuals in the event of a major accident. A Maximally Exposed Offsite Individual is a hypothetical person at the location nearest to the site boundary where individuals could normally be expected to be, such as on a main road or in a house. The distance from RLUOB to MOI is assumed to be 1200 meters. A Collocated Worker is an onsite worker 100 meters from the building. Dose is calculated by multiplying the factors in this table. The calculation is specific to RLUOB; values for some factors would differ for other buildings. The calculation assumes a worst-case accident, that is, an earthquake that collapses the building, causing plutonium-containing material to spill out of containers, followed by a fire that aerosolizes the plutonium.
The factors are as follows:
Material At Risk (MAR): The amount of material, in this case plutonium, acted upon by an event. It is measured in units of grams of plutonium-239 equivalent (g Pu-239E), a standard used to compare the radioactivity of diverse materials. Table B-1 assumes a MAR of 500 g Pu-239E; Table B-2 uses several values of MAR.
Damage Ratio (DR): The amount of damage to the structure, with 0 being no damage and 1 being complete collapse. The calculation uses a value of 1, that is, complete collapse of RLUOB, the worst case.
Airborne Release Fraction (ARF): The fraction of Material At Risk released into the air as a result of the event. ARF is specific to the type of material (e.g., plutonium oxide, plutonium metal, plutonium in solution). The material in this accident is assumed to be 90% liquid (plutonium in solution) and 10% waste (such as rags with plutonium oxide particles).
The value for ARF used in the calculation is 0.002, so this one value reduces dose by a factor of 500. Thus the dose resulting from an earthquake that collapsed RLUOB with 1,000g WGPu could be much higher than shown in Table B-1 if that value is in error. A DOE handbook shows that the factor 2E-3 (i.e., 0.002) is for airborne droplets containing plutonium oxide rather than for solid plutonium oxide particles that result from the aqueous solution containing plutonium having boiled away.   In response to a question on the validity of using that figure in Table B-1 , Los Alamos stated:  "the ARFs and RFs are almost always VERY conservative. In most of the experiments the average value was about 1 to 2 orders of magnitude lower than the value recommended for use in Safety Analysis. So, no there is not a problem. It really more goes the other way. At each stage we used very conservative values that multiply on each other, such that the final answer in no way represents reality."   Consequently, the actual dose that would result from collapse of RLUOB with 1,000 g WGPu could be tens or even 100 times smaller than shown in Table B-2 .
Respirable Fraction (RF): The fraction of the material released into the air that is of a particle size (3 microns in diameter or less for plutonium oxide) that, when inhaled, remains in the lungs. In this calculation, RF is assumed to be 1, the worst case.
Leak Path Factor (LPF): The fraction of material that escapes the building. While ARF is related to material type, LPF is related to engineered containment mechanisms, such as robust containers. In this calculation, LPF is set at 1, that is, no containment is assumed.
Source Term (ST): The amount of material released that provides dose to individuals. It is calculated by multiplying the previous five factors together. ST is then multiplied by the following four factors to arrive at dose.
Chi over Q (χ/Q): The rate at which plutonium particles are deposited (fall to the ground). It includes such factors as wind speed, wind direction, and distance from the facility to the MOI or CW receiving the dose.
Breathing Rate (BR): The volume of air, in cubic meters per second, that an individual breathes in. This is important in calculating dose because the more air an individual breathes in, other things being constant, the higher the dose.
Specific Activity (SA): A measure of the radioactivity of a material, expressed in curies (a measure of the number of radioactive disintegrations per second) per gram of material. This table shows SA for Pu-239PE.
Dose Conversion Factor (DCF): Multiplying SA by this factor converts SA to dose.
Dose is expressed in rem, a measure of ionizing radiation absorbed by human tissue.
DOE sets radiation exposure guidelines for MOI and CW in accidents that release radioactive material. The guideline dose for CW, 100 rem, is higher than that for MOI, 5 to 25 rem. The reason is that, just as workers in any hazardous occupation, such as mining or window washing, assume greater risk than the general public, so do workers in close proximity to SNM. The higher guideline reflects that risk. As noted in " Key Regulatory Terms ," one expert lists a dose of between 0 and 25 rem as having "no detectable clinical effects; small increase in risk of delayed cancer and genetic effects," a dose of 25 to 100 rem as "serious effects on average individual highly improbable," and for 100-200 rem "minimal symptoms; nausea and fatigue with possible vomiting." Thus the doses in Table B-1 and Table B-2 are very low and, as noted in "Airborne Release Fraction," above, could be much lower.
Abbreviations: MOI, Maximally Exposed Offsite Individual; CW, Collocated Worker; DOE guideline, maximum dose (in rem) per DOE regulations.
Conversion of g Pu-239E to g WGPu: The fissile material in pits is Pu-239. However, the actual material in pits, WGPu, is not pure Pu-239. Instead, it is composed mainly of that isotope as well as small amounts of other plutonium isotopes, some of which are more radioactive than Pu-239. The ratio of Pu-239 to other plutonium isotopes varies slightly from one batch to another, and the ratio changes over time as plutonium undergoes radioactive decay, with each isotope having a different rate of decay. It is useful to convert all radioactive material in a building to a single unit, in this case g Pu-239E, to facilitate compliance with MAR limits. Given the isotopic variance inherent in WGPu, no single factor can precisely convert g WGPu to g Pu-239E for all batches of WGPu. For most purposes, and for purposes of this table, multiplying g Pu-239E by 0.67 yields g WGPu.
RLUOB, as a Radiological Facility, is only permitted to hold 38.6 g Pu-239E. In order for RLUOB to do the AC and some MC to support production in PF-4 of 80 pits per year, RLUOB would probably need to hold 1,000 g of weapons-grade plutonium, though a lesser amount, perhaps 500 g, might suffice. (As noted, it is not clear that RLUOB would have the floor space to do all the AC for that rate of production.) The table shows dose resulting from an accident that released those quantities of plutonium. The table includes 2,610 g Pu-239E (1,760 g WGPu) because that is the maximum amount of plutonium that a Hazard Category 3 building can hold.
The conclusion is that even in a worst-case accident, with RLUOB collapsed by an earthquake and all plutonium in the building spilled out, converted to plutonium oxide particles by a fire, and lofted into the air, the dose that an MOI or a CW would receive if RLUOB contained 1,010 g of WGPu would be at least an order of magnitude below DOE guidelines. That would still be the case even if RLUOB held 1,760 g of WGPu.
Appendix C. Security and Hazard Categories for Plutonium
Appendix D. Preliminary Outline of Potential Tasks Required for RLUOB to Exceed Hazard Category 3 Nuclear Facility Threshold Quantity
Los Alamos National Laboratory prepared the following document to indicate the types of tasks that would be necessary to enable RLUOB to contain more than 38.6 g Pu-239E under current statutes, regulations, DOE orders, DOE standards, administrative procedures, and other requirements. These tasks would convert RLUOB to an HC-3 facility. As will be seen, the list of tasks is extensive, and tasks derive from many sources. Note that while this is a list of tasks, many of these tasks would require extensive effort to complete, and some might lead to physical changes in RLUOB, such as seismic strengthening or added safety equipment.
Appendix E. Comparison of Seismic Resiliency of CMR and RLUOB
Structural engineers strive to make buildings safe against possible earthquake ground motion. The model building codes are constantly evolving and incorporate lessons learned from the response of buildings in real earthquakes. Prior to the 1933 Long Beach earthquake, the model building codes had very few seismic requirements. This earthquake led to new requirements being added to codes. Another big change in design codes came after the 1971 San Fernando earthquake, which showed that reinforced concrete buildings with certain characteristics were prone to collapse in large earthquakes. Since that time, the codes have implemented much stricter rules for the design of both steel and reinforced-concrete buildings. 
RLUOB was designed and constructed to withstand earthquake motion much better than CMR. CMR was constructed in the late 1940s and is not very seismically robust. In fact, it is a "non-ductile reinforced concrete moment frame"—the very type of structure that the 1971 San Fernando earthquake proved to be vulnerable to collapse in earthquakes. LANL estimates that it is vulnerable to collapse in an earthquake expected to strike with a frequency of once in 167 years to once in 500 years. 
While RLUOB, as a Radiological Facility, could have been built of light-duty design and materials because it was to have only about 6 grams of WGPu, NNSA decided to build it to a much higher standard in order to understand issues that could be encountered in building CMRR-NF. Specifically, RLUOB was designed and built to the 2003 Edition of the International Building Code supplemented to meet the requirements for seismic Performance Category 2 as provided in DOE Standard 1020-2002, that is, able to withstand ground motions associated with an earthquake expected to strike with a frequency of once in 2,500 years. It has a special reinforced concrete structure for the basement, first (laboratory), and second (office) floors. The third and fourth floors, which are also for offices, are constructed of steel framing designed to the standards of an emergency response building (e.g., a hospital or fire station), so they are more seismically robust than a typical office building. As a result, RLUOB is much sturdier than it needed to be.
Based on LANL's models of seismic performance, collapsing RLUOB would take an earthquake with 4 to 12 times more force than an earthquake that would collapse CMR. Its better performance is largely the result of being able to dissipate energy through bending deformations in its steel frame. This energy absorption is key in seismic design. Brittle structures, such as CMR, cannot dissipate energy and are hence more susceptible to collapse when the ground motions exceed the building's design basis. In addition, the earthquake risk in the Los Alamos area is much better known today than it was when CMR was constructed. For example, it is now known that there is a seismic fault directly under CMR but not under RLUOB. Designing RLUOB with a more accurate understanding of the seismic characteristics of the underlying geology increases the ability of that building to withstand potential ground motion.
Appendix F. Space Requirements for Analytical Chemistry to Support Production of 80 Pits Per Year
LANL has never analyzed the space requirements for AC to support 80 ppy. However, in 2007 it analyzed the AC capacity of CMRR-NF plus RLUOB, and found that they could, together, support AC for 40-50 ppy. In the original plan for building both RLUOB and CMRR NF, there was to be a total of 16,500 square feet (sf) of laboratory space devoted to AC (see table below). If RLUOB were allowed to hold 1,000 g WGPu and CMRR-NF were to remain deferred, the amount of space for AC in RLUOB would exceed that value without incurring the operational penalty of having to use gloveboxes in PF-4 to the extent that would otherwise be required.
Regarding the latter point, a few types of AC can be done in gloveboxes. For example, sample management, which involves cutting pieces of plutonium from a larger sample, and analysis that uses solid samples on the order of 1 to 5 g of plutonium, can be done in gloveboxes because they do not require fine manipulation. In contrast, most AC uses samples of a few drops of liquid with milligram (or smaller) quantities of plutonium; such samples require fine manipulation, which is much easier to do in hoods. Performing AC tasks of the latter type in gloveboxes exacts a penalty in the time required to do the analysis, which slows throughput and thereby reduces capacity.
By performing AC tasks best suited for hoods in RLUOB and AC tasks that can be performed in gloveboxes in PF-4, by studying how to maximize efficient use of space for AC, and perhaps by using two shifts per day instead of one, it seems likely that a configuration of PF-4 plus RLUOB with 1,000 g WGPu would have the space both to fabricate 80 ppy and to provide the AC necessary to support that level of production. A detailed analysis would be needed to reach this conclusion with confidence. 
Appendix G. Abbreviations