To address the problems associated with unstable forms of plutonium and inadequate packaging for long-term storage, DOE established a standard for the safe storage of plutonium for a minimum of 50 years that sets plutonium stabilization and packaging requirements. Stabilization is achieved by heating the material to remove moisture that could lead to a buildup of pressure, which would increase the risk of rupturing a container. Plutonium storage containers designed to meet the standard consist of an inner and outer container, each welded shut. The inner container is designed so that it can be monitored for a buildup of pressure using analytical techniques, such as radiography, that do not damage the container. Containers must also be resistant to fire, leakage, and corrosion. Plutonium stabilization and packaging are completed at Rocky Flats, Hanford, and SRS, and SRS has already received nearly 1,900 containers from Rocky Flats. Stabilization and packaging are still ongoing at Lawrence Livermore and Los Alamos National Laboratories. Once stabilization and packaging are completed, DOE estimates that it will have nearly 5,700 plutonium storage containers stored at locations across the United States that could eventually be shipped to SRS. SRS’s plutonium storage plans originally called for the construction of a state-of-the-art Actinide Packaging and Storage Facility that would have provided long-term storage and monitoring of standard plutonium containers in a secure environment. DOE changed its storage plans and cancelled the project in 2001 because it expected to store the plutonium for only a few years until a facility to process the plutonium for permanent disposition was available. Instead of building a new facility, DOE decided to use two existing buildings at SRS for plutonium storage and monitoring operations: Building 105-K and Building 235-F. Building 105-K was originally a nuclear reactor built in the early 1950s and produced plutonium and tritium until 1988. The reactor was then placed in a cold standby condition until its complete shutdown in 1996. The major reactor components were removed and the facility is now primarily used to store plutonium and highly enriched uranium. Building 235-F was also constructed in the 1950s and was used until the mid-1980s to produce plutonium heat sources that were used to power space probes for the National Aeronautics and Space Administration and the Department of Defense. The building is currently used to store plutonium. After the design basis threat was changed in October 2004, SRS was forced once again to reevaluate its storage plans. Because the new design basis threat substantially increased the potential threat that SRS must defend against, Building 105-K and Building 235-F would need extensive and expensive upgrades to comply with the new requirements. SRS estimated the total cost of this additional security at over $300 million. SRS further estimated that it could save more than $120 million by not using Building 235-F for storage and therefore decided in April 2005 to consolidate plutonium storage in Building 105-K. DOE cannot consolidate its excess plutonium at SRS for several reasons. First, DOE has not completed a plan to process the plutonium into a form for permanent disposition, as required by the National Defense Authorization Act for Fiscal Year 2002. DOE proposed two facilities at SRS to process its surplus plutonium into a form for permanent disposition: a mixed oxide fuel fabrication facility to convert plutonium into fuel rods for use in nuclear power plants and a plutonium immobilization plant where plutonium would be mixed with ceramics, the mixture placed in large canisters, and the canisters then filled with high- level radioactive waste. The canisters would then be permanently disposed of at Yucca Mountain. In 2002, citing budgetary constraints, DOE cancelled the plutonium immobilization plant, eliminating the pathway to process its most heavily contaminated plutonium into a form suitable for permanent disposition. Section 3155 of the act provides that if DOE decides not to construct either of two proposed plutonium disposition facilities at SRS, DOE is prohibited from shipping plutonium to SRS until a plan to process the material for permanent disposition is developed and submitted to the Congress. To date, DOE has not developed a disposition plan for the plutonium that would have been processed in the immobilization plant. In its fiscal year 2006 budget, DOE requested $10 million to initiate conceptual design of a facility that would process this plutonium. However, it is uncertain when this design work would be completed and a plan prepared. Second, even if a plan to process this plutonium for permanent disposition had been developed and DOE were able to ship the plutonium, SRS would still be unable to accommodate some of Hanford’s plutonium because Hanford’s accelerated cleanup plans and SRS’s storage plans are inconsistent with one another. DOE approved both plans even though Hanford’s accelerated cleanup plan called for shipping some of its plutonium to SRS in a form that SRS had not planned on storing. Hanford stores nearly one-fifth of its plutonium in the form of 12-foot-long nuclear fuel rods, with the remainder in about 2,300 DOE standard 5-inch- wide, 10-inch-long storage containers. The fuel rods were to be used in Hanford’s Fast Flux Test Facility reactor. The reactor has been closed, and the fuel rods were never used. Hanford’s plutonium is currently being stored at the site’s Plutonium Finishing Plant—the storage containers in vaults and the nuclear fuel rods in large casks inside a fenced area. Hanford was preparing to ship plutonium to SRS as part of its efforts to accelerate the cleanup and demolition of its closed nuclear facilities. Although Hanford’s original cleanup plan called for demolishing the Plutonium Finishing Plant by 2038, the plan was modified in 2002 to accelerate the site’s cleanup. Hanford’s accelerated cleanup plan that was approved by DOE’s Office of Environmental Management now calls for shipping the storage containers and nuclear fuel rods to SRS by the end of fiscal year 2006 so that Hanford can demolish the Plutonium Finishing Plant by the end of fiscal year 2008. To meet the new deadline, Hanford planned to ship the fuel rods intact to SRS. Nevertheless, SRS’s July 2004 plutonium storage plan stated that Hanford would cut the fuel rods and package the plutonium in approximately 1,000 DOE standard storage containers before shipping the material to SRS. Although Building 105-K has space to store the fuel rods intact, several steps would be necessary before DOE could ship the fuel rods from Hanford to SRS. First, there is currently no Department of Transportation- certified shipping container that could be used to package and ship the fuel rods. In addition, SRS would be required, among other things, to prepare the appropriate analyses and documentation under the National Environmental Policy Act and update Building 105-K’s safety documentation to include storage of the fuel rods. Wherever the fuel rods are stored, they would have to be disassembled before processing the plutonium for permanent disposition. Hanford and SRS currently lack the capability to disassemble the fuel rods, but DOE plans to study establishing that capability at SRS as part of its conceptual design of a facility to process the plutonium for disposition. The challenges DOE faces storing its plutonium stem from the department’s failure to adequately plan for plutonium consolidation. DOE has not developed a complexwide, comprehensive strategy for plutonium consolidation and disposition that accounts for each of its facilities’ requirements and capabilities. Until DOE is able to develop a permanent disposition plan, additional plutonium cannot be shipped to SRS, and DOE will not achieve the cost savings and security improvements that plutonium consolidation could offer. According to DOE officials, the impact of continued storage at Los Alamos and Lawrence Livermore will be relatively minor because both laboratories had already planned to maintain plutonium storage facilities for other laboratory missions. However, according to Hanford officials, continued storage at Hanford could cost approximately $85 million more annually because of increasing security requirements and will threaten the achievement of the goals in the site’s accelerated cleanup plan. Specifically, maintaining storage vaults at Hanford’s Plutonium Finishing Plant will prevent the site from demolishing the plant as scheduled by September 2008. Under DOE’s plutonium storage standard, storage containers must be periodically monitored to ensure continued safe storage. Without a monitoring capability that can detect whether storage containers are at risk of rupturing, there is an increased risk of an accidental plutonium release that could harm workers, the public, and the environment. Monitoring activities must occur in a facility that, among other things, is equipped to confine accidentally released plutonium through effective ventilation and appropriate filters. In addition, the facility must have a fire protection system to protect storage containers and prevent their contents from being released in a major fire. According to the Safety Board, Building 105-K is not currently equipped with adequate ventilation or fire protection. Specifically, SRS removed the High-Efficiency Particulate Air (HEPA) filters that were used in the building’s ventilation system when it was a nuclear reactor. Such filters could prevent plutonium from escaping the building in the event of a release from the storage containers. In addition, Building 105-K lacks automatic fire detection or suppression systems. As a result, plutonium storage containers cannot safely be removed from inside the outer packaging used to ship the containers to SRS. The outer package—a 35- gallon steel drum—is used to ship a single storage container and is designed to resist damage during transportation and handling. The outer package confines the plutonium in the event the storage container inside is breached. In addition, the outer package provides an additional layer of protection from fire for the storage container inside.