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Watchblog

Lab lacks ability to estimate emergency response as it also underestimates risk

Lab lacks ability to estimate emergency response as it also underestimates risk

There has been much in the recent news about Los Alamos National Laboratory underestimating how much radiation could leak from the nuclear weapons production plutonium lab after a major earthquake and fire. Read the POGO article here.

The Defense Nuclear Facilities Safety Board Report is here.

Among other problems, LANL computer models credited sheetrock walls with surviving an earthquake.

In a recently released May report, the Department of Energy’s very own oversight Department finished a separate review titled, “Independent Oversight Review of Site Preparedness for Severe Natural Phenomena Events at the Los Alamos National Laboratory”, that also questions the Lab’s safety procedures.

The Health Safety and Security Office (HSS) of Safety and Emergency Management Evaluations performed this independent review to evaluate emergency response capabilities at the Lab and how the Lab maintained them in a state of readiness in case of a severe natural phenomena event. The review showed that LANL would have trouble responding quickly with the appropriate emergency response in the case of a serious natural event.

As one of the conclusions states – “LANL does not have an adequate means for determining quickly whether an event occurring at the CMR facility, a criticality event at TA-55 PF-4 facility, or a severe natural phenomena event at either facility involves a significant quantity of HAZMAT and requires implementation of corresponding onsite protective actions or issuance of appropriate offsite protective action recommendations.” (Pg. 38)

For example, the Emergency Action Levels currently in the Lab’s Emergency Plan Procedure:

•            Do not reflect the CMR Emergency Planning Hazards Assessment isolation and downwind protective action distances for the majority of the events

•            Do not provide Emergency Action Levels for two severe natural phenomena events (earthquake and wildland fire) in the CMR Emergency Planning Hazards Assessment

•            Use a criticality alarm system as an Emergency Action Level entry indicator for a criticality event at CMR, even though CMR is not equipped with a criticality alarm system

•            Do not use the PF-4 criticality alarm system as an Emergency Action Level entry indicator for the criticality event analyzed in the TA-55 Emergency Planning Hazards Assessment.

 

In addition, the Lab’s generic natural disaster Emergency Action Levels do not provide sufficient information to accurately categorize and/or classify a severe natural phenomena event.

And LANL’s planning for onsite protective actions and offsite protective action recommendations provided in the Emergency Action Levels did not fully consider facility or site conditions for the analyzed events.

The report continues. The Independent Oversight observed outdated and incorrect information in the current set of CMR and TA-55 PF-4 Emergency Action Levels. Further, the generic Emergency Action Levels for severe natural phenomena events were not based on the potential for or an actual uncontrolled release of HAZMAT and are not linked to protective actions or protective action recommendations.

Additionally, the pre-planned protective actions for a TA-55 PF-4 seismic event are limited to shelter-in-place when there could be high radiation levels, and no effective shelters are available.

So, we have two different government agencies questioning safety after the Lab received a record $83 million in award bonuses.

These reports are another example of why the Lab must shut down plutonium operations now.

LANL loses track of nuclear materials

LANL loses track of nuclear materials

Plutonium operations placed in standby mode

 

In an April 20, 2012 report, the Safety Board charged with oversight of defense nuclear facilities reported that the system used to track nuclear materials in the Plutonium Facility at Los Alamos National Laboratory was operating erroneously. The system apparently only kept track of 1,700 out of 13,000 containers of nuclear “materials at risk” (MAR). This omission caused the facility to exceed its limits for MAR located in individual containers and outside of gloveboxes at least 15 times.

If one is operating a facility with large quantities of fissionable nuclear materials it is very important to know where the materials are at all times because stacking too much plutonium in one place can cause a criticality event or worse. After the error was noticed, the Lab manually started to verify container MAR amounts manually.  “To date, fifteen containers, all housed in the facility’s vault, have been identified with contents that exceed the MAR limit of 7500 g WG-Pu [Weapons Grade Plutonium] equivalent.” That’s a lot to lose track of because these limits help the facility to comply with the seismic requirements of operations in the Lab’s earthquake fault zone.

Normal operations have been terminated in the 150,000 square foot Plutonium Facility and the facility has been placed in “Standby Mode.” How much does a shutdown cost taxpayers?

How long has the Lab violated these limits? The report states that the tracking error was introduced during software development, apparently due to a “miscommunication” between the software developers and the security personnel. The MAR tracker program performs other required MAR limit surveillances in the facility. Are these other surveillances reliable? This incident also calls into question other Lab software, such as programs that model contaminant transport.

It is unclear if the plutonium facility has restarted operations. The Safety Board reports usually are released about a month after they are written.new green atom

 

 

 

 

 

The Defense Nuclear Facility Safety Board Report is here.

It is still annual compensation paid for by the taxpayers

I’d like to respond to the news stories out lately concerning the Director’s salary at the Los Alamos National Laboratory. Following our press release Wednesday, the Lab released their reply. It was reported by both the Albuquerque Journal North and the LAMonitor.

LANL Says Pension Boosted Director’s Compensation By Mark Oswald / Albuquerque Journal on Fri, Apr 20, 2012

Nuke Watch assails lab salary increase By John Severance, LA Monitor, Thursday, April 19, 2012 at 12:32 pm (Updated: April 20, 9:08 am)

From the monitor article –

“According to its computations, Charlie McMillan, the LANL director, had a salary of $1,081,059 in 2011. In 2009, the salary was $800,348 and in 2005, the year before the management of the lab was awarded to Los Alamos National Security, LLC, a corporation including the University of California, Bechtel Corporation, URS and B&W, the salary was $348,000.”

BTW, it’s not our “computations.” The compensation levels we quote come from federal reporting on economic stimulus funding.

In response, the Lab states, “The majority of the figure reported under DOE stimulus funding guidelines is an increase in pension value.” Can anyone explain what this means? Our economic experts are at a loss. Until I am straightened out, which I eagerly await, the statement will mean to me that the increases of the Director/President’s annual compensation are mostly due to increased pension contributions.

Whatever it is, it is still annual compensation.

The Lab response continues – “Also included are salary, life insurance, health benefits, and other total compensation.” I repeat, whatever the “increase in pension value” is, it is still annual compensation.

The Lab response continues – “The portion of the director’s annual salary reimbursable by the government is about 35 percent of the reported figure and is comparable to previous director salaries, adjusted for inflation.” That may be true, but the remaining 65% of the $1M annually going to the LANL Director/LANS President is coming from the contractor Los Alamos National Security, LLC (LANS), of which he is president of the executive committee of the board of directors. The statement continues –  “Any amount above the federal maximum comes from LANS performance fees and is not reimbursable by the government.” But the LANS performance fees are paid by the federal government, so ultimately it is still the taxpayer that is paying the LANL’s Director’s total salary.

It is still annual compensation paid for by the taxpayers.

Before the LANL management contract was privatized and became for-profit in June 2006 the LANL Directors were getting just that salary directly reimbursable by the government.  Now they get that plus the larger LANS amount on top of it.

 

Two Upcoming Events

Two upcoming events

Sunday Mornings @ The Travel Bug
April 22, Sunday, 11 am
839 Paseo de Peralta, Santa Fe

Jay Coghlan, Executive Director Of Nuclear Watch New Mexico
in Conversation with Michelle Victoria – NukeFreeNow on the work Jay has
done over the last 22 years on nuclear safety and what Michelle is planning
for the NukeFreeNow.
http://www.journeysantafe.com/travelbug.php
Travel Bug is an independent travel specialty store in Santa Fe, NM,
839 Paseo de Peralta 505-474-1457

And

CMRR Public Meeting
Wednesday, April 25 from 6:30 – 8:30
Fuller Lodge, Los Alamos

The Chemistry and Metallurgy Research Replacement (CMMR) Project is the
Lab’s $6 billion dream facility that would enable expanded production
capabilities for plutonium nuclear weapons components. The Obama
Administration has recently proposed deferring the project for 5 years,
which will likely lead to its termination.

This will be the 13th semi-annual public meeting required as part of a 2005
settlement between DOE/LANL and an network of community groups:
• Concerned Citizens for Nuclear Safety
• Embudo Valley Environmental Monitoring Group
• Loretto Community
• New Mexico Environmental Law Center
• Nuclear Watch New Mexico
• Peace Action New Mexico
• Tewa Women United

You are invited to come and be inspired as LANL CMRR project personnel give
updates on the project while our network of community groups give updates of
our concerns.

Defense Dept. Memo Criticizes Cost of Nuclear Weapons Labs While Los Alamos Director’s Salary Nearly Triples

Our colleagues and friends at the Project on Government Oversight (POGO) have released an explosive report based on a leaked Department of Defense memo concluding that “The Department of Energy’s network of privately-operated nuclear weapons laboratories are riddled with waste, redundancies and lackluster scientific standards.” POGO also found that “that seven of the top 15 officials at the three DOE nuclear labs make more than $700,000 per year, with one earning $1.7 million—more than the president of the United States and many government executives.”

Coincidentally, Nuclear Watch New Mexico had been independently compiling data on the salaries of the three laboratory directors, as presented in the table below. It shows that the salary of the Los Alamos Director has nearly tripled since for-profit management began in June 2006, even as the Lab is cutting some 600 jobs. As seen below, privatization of the nuclear weapons labs’ management contracts has resulted in directors’ salaries far above average in both the federal government and the private sector.

 

 

The DoD memo leaked by POGO contains the following admirable passage on good governance:
Diminishing Public Accountability. Without a strong yardstick, our government cannot govern well — not even if it retains the best and brightest on contract. The government’s own assets must capably bear the responsibility for decisions that affect national interests, and they must maintain public confidence by the manner in which those decisions are made.

In contrast, the directors of the three nuclear weapons labs (the Los Alamos, Sandia and Lawrence Livermore National Laboratories) wear two hats, first as lab directors, but secondly as the presidents of the board of directors of the for-profit limited liability corporations (LLCs) that run the labs. That may be a questionable conflict of interests, in which the LLCs are enjoying record profits from issues that deeply “affect national interests” (i.e., nuclear weapons) while the salaries of their “CEOs” (the lab directors) are exploding.

Arguably the lab directors have not maintained public confidence in the decisions they make because of the general trend of increasingly withholding crucial public information. One example is the Performance Evaluation Reports that rate contractors’ performance and determines the amount of taxpayers’ money awarded to them. Those reports were publicly available until 2009 when the National Nuclear Security Administration (NNSA) began to withhold them, and became recently available again only after NukeWatch NM sued for them under the Freedom of Information Act.

NNSA awarded the limited liability corporation that runs Los Alamos Lab $74.2 million for FY 2010, followed by $83.7 million in profit for FY 2011, a 13% increase in one year, and 10 times more than what the University of California (UC) use to be awarded when it was LANL’s sole nonprofit manager. Jay Coghlan, NukeWatch Director, commented, “In today’s political and economic climate citizens need to remain vigilant that for-profit corporate interests don’t corrupt serious national issues. This very much applies to how our nuclear weapons labs are run as well. We specifically call upon Los Alamos Lab to fully explain to northern New Mexicans why it needs to cut some 600 jobs while at the same time the for-profit management corporation is enjoying record profits and the Director’s salary has nearly tripled in six years.”

# # #

All data on nuclear weapons labs directors’ salaries are from:
http://www.recovery.gov/Transparency/RecipientReportedData/pages/RecipientProjectSummary508.aspx?AwardIdSur=74953
http://www.recovery.gov/Transparency/RecipientReportedData/pages/RecipientProjectSummary508.aspx?AwardIDSUR=115066&qtr=2011Q1
http://www.upte.org/LosAlamos/salaries/salaries.html

POGO’s press release “Leaked Defense Memo Criticizes the Department of Energy’s Push to Expand Nuclear Weapons Laboratories” is at http://www.pogo.org/pogo-files/alerts/nuclear-security-safety/nss-nwc-20110418-nuclear-waste-dept-of-energy.html

POGO’s detailed letter to congressional committees on these issues is at http://www.pogo.org/pogo-files/letters/nuclear-security-safety/nss-nwc-20120418-nuclear-weapons-labs.html

To read the leaked DoD memo, click here http://pogoarchives.org/m/nss/new-missions-for-the-nuclear-weapons-labs-11-16-2011.pdf

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Love and Loss in the Jemez

We’re lucky in that it appears Los Alamos Lab has dodged the bullet with respect to the Las Conchas Fire, but I do want to say something about 100,000 acres of some of the most beautiful land in New Mexico burning up in the Jemez Mountains. I know it fairly well.

Back in the early 1980’s I would take my kids out on a full moon night in the winter after it snowed on Highway 4 near the Valle Grande and pull them on an upside down car hood chained to my pickup (not recommended, but they loved it). I use to rock climb a lot at the Las Conchas Canyon on the east fork of the Jemez River (near where the fire broke out), and down at the southern end of the fire at Cochiti Mesa and Eagle Canyon (the erosion in Eagle Canyon after the 1996 Dome Fire was shocking, a harbinger of what is to come with this fire). I remember taking my kids to the beautiful Santa Clara Canyon to the north, which the fire is now devastating (my heartfelt condolences to the Pueblo). My parents took photos of me and my two brothers when we were small in the late 1950’s sitting in a Bandelier National Monument “cavate” (a hole in the canyon volcanic tuff further carved out by the Anasazi to live in), posing as the three little monkeys who hear no evil, see no evil, speak no evil.

As an adult I’ve been back country many times in Bandelier (now half burned), where on a map it looks like you walk say 5 miles but it will actually be eight by the time you climb up and down canyons. I know of a ponderosa pine in the Jemez where a buddy bigger than me (and I’m six feet) and I could not touch our fingers together while hugging its girth. I’m a tree hugger, but I also had chain saw thinning contracts all over the Jemez, including one on the south rim of the Frijoles Canyon above Bandelier (where thinning is sorely needed). I would occasionally run across unexcavated Anasazi pueblos and walls.

I’ve seen acres of trees in the Jemez covered with monarch butterflies during their migration to Mexico.

All this burned area is beautiful, beautiful country – beautiful forests, hoodoo rocks, clear streams, elk, bear, deer, eagles, hawks, peregrine falcons, ponderosa, pinon, alligator juniper in the south, blue spruce up high, New Mexico turquoise skies, deep snows in winter (in a good year) and hot springs.  These beautiful Jemez Mountains (not really peaks, but the more you know this land the more it grows on you). Are typically wetter than most of New Mexico, but this year so dry, and burning.

I pray that the trees, animals and the rains come back. But we humans must do our part, in the near term taking preventative measures against what could be devastating erosion now that the trees and grasses are gone. We need better forest management practices that allow fire to periodically sweep the forests (ponderosa pine evolved to adapt to and benefit from these low intensity fires), instead of suppressing them to the point where catastrophic crown fires break out. Longer term we need to begin to grapple effectively with global climate change, otherwise we may never get our Jemez forests back.

And we should comprehensively clean up Los Alamos Lab, because while it dodged the bullet this time, it may not the next time.

Beautiful, beautiful Jemez land, much of it gone – I love it and now I’m deeply missing it.

Jay Coghlan, Executive Director of Nuclear Watch New Mexico
Jay Coghlan, Executive Director of Nuclear Watch New Mexico

 

Still Time to Comment on LANL’s Burning Desire for Expanded Weapons Production

Ironically today (June 28) is the deadline for public comment under the National Environmental Policy Act (NEPA) for concerned citizens to comment on a proposed ~$5 billion facility at the Los Alamos Lab ponderously called the Chemistry and Metallurgy Research Replacement Project- Nuclear Facility. In short, it is a huge new plutonium facility that will provide materials characterization and analytical chemistry in direct support of production of the atomic cores or “triggers” of nuclear weapons, commonly called the plutonium pits. The Nuclear Facility will be the keystone to an expanded complex at LANL’s Technical Area-55 that will quadruple production capacity from 20 to 80 pits per year.

I say ironically because of the fire that is now threatening the Lab. We need to begin questioning whether expanded nuclear weapons production at Los Alamos is feasible in a possibly long-term drought and climate warming punctuated with catastrophic forest fires. More broadly, as we face increasing budget and resource constraints, we need to decide whether our money and water go into expanded nuclear weapons production, or do they go into repairing schools and infrastructure for the common good of society?

 

The Risk to Waste Stored at Area G

We pride ourselves here at Nuclear Watch New Mexico on trying to stick to the facts as we best we know them and not being alarmist. That said, the Las Conchas Fire that has now crossed the Los Alamos National Laboratory’s (LANL’s) southwestern boundary is a real threat. For starters is the mind-blowing fact that in just 30 hours this fire has grown bigger than the notorious 2000 Cerro Grande Fire which burned ~48,000 acres (~5,000 acres within Lab boundaries), and traveled in a beeline 12 miles to get to the Lab. With forecasted days of strong winds and gusts and high temperatures it’s hard to say where this fire might go and what it might do. Pray for rain.

We are not so concerned about the hardened facilities at the Lab constructed of concrete and cleared of combustible materials (i.e., trees and brush) around their perimeters. We doubt that there would be any breech to their containment that would let contaminants escape (with one caveat below). But we do have concerns. One is the fact that over 6 decades the Lab has blown up a lot of uranium and depleted uranium in dynamic high explosives experiments in the general area in front of the fire. We don’t know to what extent the shrapnel or debris has been cleaned up and could possibly be aerosolized.

Another concern, given both the velocity and ferocity of the Las Conchas Fire, is whether any Lab facilities loose their power and back up generators failed to work for whatever reason. In that case containment systems could fail with unknown safety implications.

LANL TA-54 Material Disposal Area G
Domes at LANL's TA-54 Material Disposal Area G

But our biggest concern is whether the fire could reach the fabric buildings (essentially very large tents) at Technical Area-54’s Area G that store some 20,000 barrels of plutonium-contaminated wastes from nuclear weapons research and production. We recommend that the public use satellite-based fire detection data and fire intelligence information published by the US Forest Service to monitor the situation (see related post for instructions on how use it). From that we can “see” that the leading edge of the fire is a little more than three miles from Area G.

The good news is that the fire should slow down if and when it heads toward Area G because it will have to leave the mostly ponderosa forest into pinon and juniper country (which doesn’t crown fire like ponderosa). Also, the Lab has cleared trees and vegetation around Area G, and the fire would have to jump some major canyons just to get there.

So here’s hoping the fire doesn’t get anywhere close to Area G. But watch out if it does. The public should be concerned and really pay close attention. It might be a good time to take a road trip somewhere away from being downwind. This is one fire that cannot be underestimated.

 

Extensive B61 Life Extension Serves Lab’s Self-Interest More than Weapon’s Mission

To add to the uncertainty surrounding the pending B61 Life Extension Program:

The NNSA’s FY 2012 Congressional Budget Request says that among other things the scope of the B61 LEP will include “implementation and maturation of enhanced surety technologies into the nuclear explosive package,” a major rationale for the program to begin with. B61 surety is especially sensitive given their forward deployment in Europe.

During the last few months I have learned the following from anonymous congressional staff:

•           Prestigious consultants to the government (the JASONs) finished a study in January or February on the surety of US nuclear weapons. It is classified with no unclassified summary. One aim of the study (perhaps the aim) was to create baseline criteria for applying surety mechanisms to existing US nuclear weapons.

•           In that study the JASONs raised some concerns that NNSA-proposed enhanced surety technologies could impact nuclear weapons reliability. NNSA is now in the process of responding that its enhanced surety technologies are maturing.

•           Some congressional staff seriously doubts these new surety technologies will be mature enough for inclusion in the B61 LEP if it starts as scheduled in FY 2012 (which begins this October 1). If I understood correctly, these concerns revolve around multi-point safety and optical detonation. It’s not clear to me whether or not the JASONs share these particular concerns.

•           The JASONs are also in the process of preparing a separate cost benefit study on the proposed B61 LEP.

To be clear, I have no way of independently verifying the above, nor do I have a full (or even good) understanding of their implications. It is obvious that the B61 LEP is a very big deal to the nuclear weapons labs. For example, Sandia calls it “the largest effort in more than 30 years, the largest, probably, since the original development of the B61-3, 4, a full-up weapon development effort that began in the late 1970s and entered the stockpile in 1979.” (“Launching the B61 Life Extension Program,” Sandia Lab News, March 25, 2011).

NNSA and the nuclear weapons labs seem anxious to rush the B61 Life Extension Program now before the political momentum of increased nuclear weapons funding as a condition of New START ratification begins to recede. To the contrary, we should hit the pause button on the B61 LEP instead of automatically following the labs’ vested self-interests. In order to prudently conserve taxpayers’ dollars, the B61 LEP should be delayed for a few years while new surety technologies and other issues (such as continuing forward deployment in Europe) are sorted out.

 

Replacement of Neutron Generators is Routine

At a town hall meeting this week in Oak Ridge, Tennessee, near the proposed location of the new “UPF” nuclear weapons facility at the Y-12 National Security Complex, the state’s junior senator, Bob Corker quipped:

It’s just about the fact that our nuclear arsenal is absolutely obsolete. I saw neutron generators, literally, out in New Mexico that will quit working in the year 2015, which means it renders the weaponry totally obsolete.

Whew. Stunning.

Neutron generators are “limited life components” (LLCs). The NNSA FY 2012 Congressional Budget Request has this to say: Many age-related changes affecting various nuclear warhead components are predictable and well understood. Limited life component exchanges are performed routinely to replace these components periodically throughout the lifetime of the weapon. Components such as power sources, neutron generators and tritium reservoirs deteriorate predictably and must be replaced before their deterioration adversely affects function or personnel safety. Page 50, emphasis added.

Changing out neutron generators in fact appears so routine that it seems the military changes them out in the field. A July 1995 Bulletin of the Atomic Scientists (p. 78) mentions “On April 11, [1995] Sandia delivered 36 recertified neutron generators to the Navy…” Emphasis added.

NNSA says under FY 2010 Accomplishments for Stockpile Systems: “Delivered all scheduled LLCs (GTS [gas transfer systems, meaning tritium] reservoirs and neutron generators (NG)) and alteration kits to the DoD and Pantex to maintain the nuclear weapons stockpile.” NNSA FY 2012 Congressional Budget Request (CBR), p. 61, emphasis added.

Also of interest on the same page: “Selected a common NG for the B61 and B83 that will reduce development, production, and maintenance costs.”

Neutron generators are testable, and the testing devices themselves are being improved. “FY 2010 Accomplishments Stockpile Readiness Nonnuclear Readiness… Deployed Neutron Generator (NG) Testers, which assures neutron generator test capability by modernizing testers as required to support NG production and shelf-life programs.” NNSA FY 2012 Congressional Budget Request, p. 135.

A MC4380 Neutron Generator for the W76-1
Neutron Generator, Sandia Lab News, March 2011

In the current Life Extension Program W76-1’s are being outfitted with new-design neutron generators (the MC4380). Corker is seeing neutron generators in New Mexico because Sandia produces them and loads tritium into the neutron target tubes that are a critical part of neutron generators. Production of neutron generators is being both improved and expanded.

This from Sandia Labs “Labs Accomplishments:”

During FY10, Sandia shipped more than twice as many neutron generator assemblies (NGAs) to its NNSA and military customers than in any previous year. This totaled 850 NGAs and 340 packaging requirement kits. Record completion rates were achieved in four different production areas within the neutron generator supply chain, in concert with a shift to a common neutron generator subassembly that improved production efficiency. Sandia established a balanced supply chain capacity approach to help meet future NG directive schedule challenges with a diverse neutron generator product mix supporting numerous weapon systems.

http://www.sandia.gov/LabNews/labs-accomplish/2011/lab_accomp-2011.pdf, p. 5

Neutron generators themselves are being continuously improved, for example:

In the early 1990s Sandia undertook to design a replacement neutron generator for the W76 nuclear warhead on the Mark 4 reentry body of the Navy’s Trident I system. There were several compelling reasons for doing so, including the need to increase the component’s design margins, simplify its manufacturability, augment its resistance to new profiles of hostile environments, and increase its life span.

http://www.globalsecurity.org/wmd/systems/w76.htm

In 1999 the MC4380 Neutron Generator and its MC4378 Timer, MC4705 Voltage Bar, MC4148 Rod, MC4437 Current Stack, and MC4277 Neutron Tube were qualified for use in the Navy’s W76 weapon system. This culminated a multi-year development effort which included the transfer of production capability from the Pinellas Plant to Sandia. This is the first weaponized neutron generator to employ a focused ion-beam neutron tube for higher reliability, the first produced at Sandia, and the first Sandia component with radiation hardness requirements to be qualified without underground testing.

http://www.globalsecurity.org/wmd/systems/w76.htm

The neutron generator business is very robust, and Corker’s claims of obsolescence are absurd.

 

 

 

Big Money for the B61’s New Ride

In a mid April report to Congress, the Pentagon stated lifetime cycle costs of the dual [nuclear] capable F-35 Joint Strike Fighter  will exceed $1 trillion. The F-35 will have a lot to do with future forward deployment in Europe (or not) of the proposed heavily modified B61-12 tactical nuclear bomb.

According to Inside Defense, problems with development and production aspects of the F-35 program will delay the deployment of the aircraft another two years and require an additional $7.2 to complete the development phase.

Ironically, Lockheed Martin is the lead contractor for the F-35. It is also the contractor that runs the Sandia National Laboratories, which is the lead lab for the B61 Life Extension Program (LEP). One of the main purposes of that LEP is transform the B61 “analog controlled” bomb into a “digitally controlled” bomb that mates with the advanced electronics and avionics of the F-35.

The B61 LEP will begin in FY 2012 with $223.6 million in funding. Total cost is currently estimated at ~$5 billion

The Corporate Folly of Nuclear Power

Meltdowns at the reactors are not the biggest threat, as horrific as they are. Instead the biggest threat is the spent fuel rod pools if they lose circulating water.

The reactors at Fukushima were designed by US General Electric, whose corporate slogan is “bringing good things to life.” The Fukushima reactors had their back up diesel generators at ground level, hence a few feet above sea level, and their spent fuel pools on the “top deck” of the reactor buildings, the equivalent of 3-4 stories up. When the earthquake knocked out the electric power required to circulate absolutely essential liquid coolant the diesel generators kicked in as designed. So far so good.

But then the diesel generators were wiped out 55 minutes later by the tsunami (duh!, the Fukushima nuclear power complex is right on the coast – didn’t the “experts” think of that?). The resulting lack of circulating water has precipitated this crisis that is now on the verge of being an unprecedented catastrophe. A spent fuel rod fire can release far more radioactivity than Chernobyl (see below).

The pathetic irony is that to prevent this catastrophe Tokyo Electric MUST get circulating water UP to the spent fuel rod pools because the diesel generators were swamped DOWN below. The placement of the generators and the waste pools relative to each other was exactly and tragically back *sswards. Do not trust “EXPERTS!,” meaning that citizen activism is always required. IT IS A MUST!

I shun hysteria, but this situation is way serious, it could really get out of control. Pray for the Japanese people, already the victims of history’s only two (so far) atomic attacks. If the fuel rods go count this as the 3rd attack, albeit self-inflicted. Nuclear operations require perfect human operation 24/7/eternity (i.e., as long as we run them). Humans are fallible, and nature can shrug us off like flies.

Get rid of nukes, period (except medicine). It takes only once on the balance sheet to wipe out any potential benefits, and indebt seven future generations environmentally, economically, politically and genetically all at the same time. It’s NOT worth it.

To end on a cheery note (not!): “As flies to wanton boys, are we to the gods. They kill us for their sport.” Shakespeare’s King Lear, 4. 1. The gods may do what they want, but don’t let international corporate nuclear power interests kill us. Fight back!

Mother Earth Gives Nuclear Renaissance a Black Eye

Our hearts and prayers go out go out to the people of Japan.

As Japan is faced with the possibility of nuclear meltdowns in five earthquake-damaged nuclear reactors, the U.S. and other countries are re-considering nuclear plans. While it is unlikely that radiation that has leaked or will leak from the Japanese reactor accidents will reach the United States.  This could change if there is an explosion and/or fire affecting one or more of the reactor cores or spent fuel pools. The accident at Chernobyl (25th anniversary is April 26th) affected the entire Northern Hemisphere because of a massive explosion in the core, and an out-of-control fire that burned for days.  This same scenario is unlikely in Japan. But reactors have been damaged beyond repair and old questions are being raised again.

In the U.S., Sen. Joe Lieberman (I-Conn.) and Democratic Rep. Ed Markey of Massachusetts have made statements – “But I think we’ve got to kind of quietly put, quickly put, the brakes on until we can absorb what has happened in Japan as a result of the earthquake and the tsunami and then see what more, if anything, we can demand of the new power plants that are coming on line,” Lieberman stated. “Any plant that is being considered for a seismically vulnerable area in the United States should be reconsidered right now,” Markey said, adding that the Japanese earthquake registering 8.9 in magnitude was “a hundred times greater in intensity” than the level that U.S. plants are built to withstand.

Countries in Europe are pausing to re-consider, also. Japan’s nuclear emergency Monday prompted Germany and Switzerland to halt nuclear programmes as anxious Europe scrambled to review cross-border safety while safeguarding the powerful industry. More

Why were the Fukushima reactors at sea level? Japan’s nuclear accident exposes the dilemma of whether to build power plants on tsunami-prone coasts or inland sites where water supplies are unreliable, a problem likely to be aggravated by climate change, experts say. (More from Reuters)

What happened at the Fukushima plant? “Three of its six reactors were in operation when the earthquake hit. The reactors — which went into service between 1970 and 1979 — are designed to shut down automatically when a quake strikes, and emergency diesel generators began the task of pumping water around the reactors to cool them down. However, these stopped about an hour later. The failure of the back-up generators has been blamed on tsunami flooding by the International Atomic Energy Agency (IAEA).” More –

This event shows how Mother Earth can have her way with the best-made plans. The power company said that that 7.9 was the highest magnitude for which they tested the safety for their No. 1 and No. 2 nuclear power plants in Fukushima. The original magnitude was estimated to be 8.9, which would have been 10 ten times the magnitude 7.9 that the structures were tested for. The Japan Meteorological Agency up-rated Friday’s earthquake to 9.0 on the Richter scale, meaning that it was twice as powerful as initially thought. More

Here at home, we have no commercial reactors in New Mexico, but there are national nuclear weapons facilities, including Los Alamos National Laboratory, which currently has plans for a $5 billion addition to the Lab’s plutonium weapons production complex. This addition, called the Chemistry and Metallurgy Research Replacement project Nuclear Facility (CMRR-NF) is being designed to survive a 7.0 magnitude earthquake without releasing plutonium.  Much of the estimated cost is to seismically qualify the CMRR-NF to be built on the fault-ridden Pajarito Plateau. The plans call for a storage vault with the capacity of six metric tons of radioactive materials, such as plutonium.

Now would be a good time to re-consider any plans that make us feel invincible.

 

CMRR FY2012 Budget Request – Blank Check or Black Budget?

CMRR FY2012 Budget Request – Blank Check or Black Budget?

The FY2012 budget request shows $300 million for the Chemistry and Metallurgy Research Replacement (CMRR) Project, which is now estimated to cost a total of $6.22 billion. $29.9 million is requested for equipment in the recently completed first building, the Radiological Laboratory/Utility/Office Building (RLUOB). But exactly how will the remaining $270 million be spent? That’s literally “TBD” (To Be Determined). What a great deal – receive $270 million and then decide what to do with it. How lucky the Lab must feel to get a blank check in this era of fiscal restraint.

Is the Lab planning to use some of the $270 million to begin construction of the huge “Nuclear Facility”? Because there is a Supplemental Environmental Impact Statement (EIS) now underway for the NF, any construction funding now could prejudice any decision, or at least would smell like prejudice. A more likely scenario is that the Lab figures that it might be able to stash funds away in some black budget to use on construction later, in effect creating a slush fund that would insulate it from and possible future budget cuts.

Perhaps going back to last year will offer some clues. The FY2011 Congressional Budget Request projected that LANL would ask for a total of $322.1 million for FY2012.

The FY2011 breakout estimated for FY2012 was:

$29.9 million RLUOB Equipment Installation (REI) [This turned out to be exactly the amount requested for FY2012.]

$3 million for Other Project Costs (OPC) [This turned out to be “TBD” for FY 2012.]

$102.8 million for NF design [This turned out to be “TBD” for FY 2012. Not counting any FY2012 funding, $419 million has been spent to date on design of the NF.]

$186.4 million for NF construction [FY2012 was to be the first year that construction funds were to be requested for the NF. This turned out to be “TBD” for FY 2012. But it really should be “0” because there is a SEIS underway.]

If all of the $270 million requested for FY2012 is not for NF design, we deserve to know what it’s for.

Regarding NNSA’s Defense Nonproliferation Programs and MOX

I think it would be a big mistake to give unqualified support to restoring funds for NNSA’s Defense Nonproliferation Programs. In my view the best thing that could be done for those programs would be to kill the Mixed Oxide reactor fuel (MOX) program and revive immobilization for ultimate plutonium disposition.

I endorse the strategy of cutting MOX so that the other nonproliferation programs could be spared cuts. I suspect that may be more politically feasible rather than trying to persuade Congress to transfer money from nuclear weapons programs to nonproliferation. [Having said that, I will be trying to cut weapons $$$ regardless.]

I am actually somewhat impressed by the House proposed cuts, after they did propose a 12.8% cut to the requested FY11 NNSA Total Weapons Activities, so apparently there are no sacred cows. I think a cost benefit argument could be made in that the other nonproliferation programs save us money in the long run by discouraging/suppressing nuclear weapons proliferation, whereas there is no economic benefit that I am aware coming from the MOX program (which will probably become a heavy economic liability anyway).

The FY 2011 request for total Defense Nuclear Nonproliferation was $2,687,167,000. In the on-deck continuing resolution to fund the remainder of FY 2011 the Republican-controlled House Appropriations Committee wants to cut it to $2,085,200,000.  A full 27% of the FY11 Nonproliferation request is dedicated to the MOX program under Fissile Materials Disposition. MOX is arguably a proliferating program instead of a nonproliferation program (never mind potential safety problem and taxpayer giveaways to the nuclear industry).

FY 2011 Request for Fissile Materials Disposition:
Irradiation, Feedstock, and Transportation = 107,787,000
MOX Fuel Fabrication Facility at the Savannah River Site = 475,788,000
Waste Solidification Building (SRS) = 57,000,000
Pit Disassembly and Conversion Facility Construction  (SRS) = 80,000,000
Total = 720,575,000

There is nearly 3/4 billion dollars for MOX in the FY11 request. In contrast there is only $29,985,000 in the FY11 request for Uranium Disposition, which is mostly  down blending of the immense stores of weapons-grade highly enriched uranium at

Y-12 (the Project on Government Oversight estimates 200-300 metric tons). As far as Fissile Materials Disposition goes that should really be prioritized.

Maybe MOX could be low hanging fruit now, but beware that the MOX Fuel Fabrication Facility (MFFF) is now something like more than 50% constructed. Further, the Advanced Recovery and Integrated Extraction System (ARIES) at LANL’s Plutonium Facility-4 is lined up to provide the first two metric tons of feedstock. If something is to be done about MOX it should be done in the near term.

LANL Gestures to Gas Shortage

In response to statewide natural gas outages across New Mexico, LANL closed February 4th. The gesture may reflect that LANL gas use is roughly the equivalent[1] of 22,310 people, nearly the same as the 25,000 people that media reports are without recent service.

Although shutting down LANL would almost make up for the shortage in gas affecting northern New Mexico, it is not quite that equitable. LANL and the Los Alamos town site have their own dedicated gas pipeline coming from the NW San Juan Basin, in New Mexico. Whereas Albuquerque, Santa Fe, Espanola, Taos etc are fed natural gas from the Permian Basin gas fields in Texas. Therefore it is questionable that curtailing operations (which cost taxpayers ~$6 million/per day) at LANL helps to relieve gas supplies in northern New Mexican communities.

It also begs the question of why aren’t Northern New Mexico gas supplies coming from the plentiful San Juan basin, one of the largest reserves in the nation, which is geographically closer? Espanola and Taos are reportedly suffering in recent subzero temperatures because they are at the “end of the line” of gas coming from Texas. But the privileged Lab and Los Alamos town site would not be subject to the same short supply.


[1] According to the 2006 LANL Site-Wide Environmental Impact Statement the Lab uses an average of 37.4 million cubic meters of natural gas annually, or 1.32 billion cubic feet (1 cubic meter = 35.31 cubic feet). Wikipedia says Americans use 18.4 trillion cubic feet per year. U.S. population is around 311 million people, hence per person use = 59,164 cubic ft/yr. Population of Espanola = ~10,000, hence uses ~ 591,640,000 cubic ft/yr. Population of Taos = 5,550, hence uses ~ 328,360,200 cubic ft/yr. Therefore, LANL uses twice as natural gas as Espanola, 4 times as much as Taos. TA-55 (site of plutonium pit production) alone uses 45 million cubic ft per year.

Nuclear Science Week, by the makers of the “Bomb”

This press release from NNSA is really deceptive. The words “nuclear” and “science” are used quite a bit, but “weapons” only like in “As we continue to turn a Cold War nuclear weapons complex into a 21st century nuclear security enterprise.” The uninformed reader would get the impression that NIF, DARHT and the Z machine are not really about nuclear weapons, when of course they are.

Also, the uninformed might get the impression that the National Ignition Facility has already achieved ignition, which couldn’t be farther from the truth (and it’s doubtful that NIF ever will achieve ignition). Nor is DARHT yet working as advertised, even after more than a decade of operations.  And then there are the cost overruns: NIF from ~$1 billion to ~$5 billion and DARHT from ~$35 million to ~$275 million, not including dubious reprogramming of other monies for both projects.

And supercomputers fighting AIDS and bringing “products to market faster” (can you spell j-o-b-s?). It’s a wonderful world, this “21st century nuclear security enterprise.”

I cringe to think that a congressional staffer (or anybody) would read stuff like this and think it true.

NNSA Will Not be “Burdened” by Costs for Clean-Up at New KCP

I found what I think is an interesting quote concerning the new KCP  in NNSA’s FY 2011 Stockpile Stewardship and Management Plan (which is the plan that NNSA showboats to Congress).

“Finally, because the new facility [KCP] will be leased, there will be no capital investment and NNSA will not be burdened by costs for legacy disposition should the mission ever be discontinued.”   NNSA FY11 SSMP Annex D, p. 44,

This sounds to me like the federal government is walking away from any future obligation to clean up any contamination at the new Kansas City Plant. I think that interesting given how there is no real federal commitment to clean up the old plant which is badly contaminated.

The rest of NNSA’s FY 2011 Stockpile Stewardship and Management Plan (summary and Annex A) can be viewed.
Annex B and C are classified.

If NNSA won’t be burdened for clean-up, who will?

Weight Restrictions for Weapons Workers?

Question: What is the tripping-man impact scenario for a nuclear weapons production technician?

Answer: A 280 lb production technician traveling 2 .5 miles per hour.

We are all familiar with the horrible impacts that nuclear weapons have on humans, but now we have an Analysis of Human Impacts on Weapons. The Defense Nuclear Facilities Safety Board (Board) recently reviewed the Hazard Analysis Reports (HARs) for several nuclear explosive operations at the Pantex Plant and found that Plant could have a weight problem with its production technicians (PTs).

Of concern is that the weapons design agency supplies data on weapons responses for “tripping-man impact scenarios” based on the energy imparted by a 280 lb PT traveling 2.5 miles per hour. Tools and parts could break if someone larger tripped into a warhead while going faster that 2.5 mph. And Pantex has no controls in place to limit these human impact energies.

The DNFSB concluded that the “maximum PT impact energy does not represent an uncontrolled environment, such as lightning, earthquake, or meteorological conditions.” Pantex imposes other physical qualifications for PTs (such as age, sight, speech), as well as other limitations specified by the Human Reliability Program. They believe that weapon responses should be reevaluated for higher impact energies, or that Pantex should limit PT weights.

Once Again – It’ll Cost More and Take Longer

Decades of nuclear materials production at the Department of Energy’s (DOE) Savannah River Site in South Carolina have left 37 million gallons of radioactive liquid waste in 49 underground storage tanks. This is just a small part of DOE’s Cold War cleanup legacy that currently has an estimate of $360+ billion to remediate across the country. This estimate keeps going up.

The United States Government Accountability Office released a September 2010 report about persistent concerns with efforts to cleanup these underground radioactive waste tanks. Like so many GAO reports before, the findings are that it will cost more and take longer:

Emptying, cleaning, and permanently closing the 22 underground liquid radioactive waste tanks at the Savannah River Site is likely to cost significantly more and take longer than estimated in the December 2008 contract between DOE and Savannah River Remediation, LLC (SRR). Originally estimated to cost $3.2 billion, SRR notified DOE in June 2010 that the total cost to close the 22 tanks had increased by more than $1.4 billion or 44 percent. Much of this increase is because DOE’s cost estimate in the September 2007 request for proposals that formed the basis of the December 2008 contract between DOE and SRR was not accurate or comprehensive.

Legacy cleanup at Los Alamos is currently estimated by the Lab to be around $2-3 billion.  This is required to be complete by 2015 by a consent Order agreement with the State of NM.  This estimate includes the Lab’s version of cleanup, which is leaving most the waste in the ground perched above our aquifer. Actually removing the waste is estimated at $20 billion. The final decision on what type of cleanup will be made by the State, which would like to have you the public’s input.

Cleanup at Los Alamos is one project that needs to cost more.

CMRR is Key to Expanded Plutonium Pit Production

While being narrowly correct, LANL PR man Kevin Roark is misleading when he claims [in a June 25, Letter to the Editor of the Santa Fe New Mexican  newspaper] that plutonium pit production will not take place in the new Chemistry and Metallurgy Research Replacement Project (CMRR). What he fails to disclose is that the Lab is not building just one facility, but instead is creating an integrated manufacturing complex for expanded production for which the CMRR is absolutely key. This complex will consist of LANL’s existing production facility “PF-4” with ~$300 million in upgrades; CMRR’s already completed first phase, the $400 million “Rad Lab”; and the future $4 billion CMRR “Nuclear Facility,” now being debated.

The Nuclear Facility will be literally next door to PF-4 and linked to it via underground tunnel. While pits are physically manufactured in PF-4’s glovebox lines, the Nuclear Facility’s central missions of “materials characterization” and “analytical chemistry” are essential operations that ensure “weapons-grade” plutonium and pit production quality control. The National Nuclear Security Administration’s own documents show that the Nuclear Facility is being specifically sized to support expanded production of up to 80 pits per year, quadruple LANL’s currently approved rate. It is also planned to have a vault for up to six metric tons of “special nuclear materials,” capable of storing around 1,000 pits.

Roark must think that New Mexicans are naïve enough to accept the Lab’s claims that the CMRR is all about “science” even as LANL becomes more and more a production site. Sadly, this is only part and parcel of the substantial rebuilding of the U.S. nuclear weapons production complex, which will also include a new $3.5 billion Uranium Processing Facility in Tennessee and a new privately financed Kansas City Plant for production of the 1,000’s of nonnuclear components that go into a nuclear weapon.

Many New Mexicans hoped for serious mission diversification at Los Alamos, which some $5 billion sunk into its plutonium infrastructure will almost certainly shut the door on. Schools in Santa Fe and all across the country are being closed due to lack of funding. Nevertheless, our government is preparing to spend some $10 billion to build new production plants even as we are purportedly working toward the declared long-term national security goal of a nuclear weapons-free world. To get there, citizens need to push the politicians to meet the needs of everyday people, not those of the vested nuclear weaponeers.

Revised Estimates for Safer Gloveboxes Hurt Budget

On the heels of a GAO report made public Monday, which stated that accounting procedures used by various branches of the U.S. nuclear weapons complex are preventing NNSA from pinpointing the exact total cost of maintaining its nuclear deterrent, the Defense Nuclear Facilities Safety Board (DNFSB) has released a weekly report also showing LANL’s inability to accurately estimate even the tiniest of specific costs.

In the June 4th weekly report for Los Alamos Lab, the DNFSB stated that the Lab underestimated the cost of seismically upgrading gloveboxes at its plutonium pit production complex by an order of magnitude. The DNFSB stated, “…the expected cost of seismic upgrades to individual gloveboxes has risen from an original estimate of about $80,000 per glovebox to a current estimate of approximately $850,000.” In addition, the Lab also ended up doubling the number of gloveboxes that need the upgrades as a priority up to 157.

So, in effect, the Labs original estimate for this glovebox work was $6.4 million (80 gloveboxes at $80,000 each), but the revised estimate is now $133.4 million (157 gloveboxes at $850,000 each). It’s hard to understand how new bracing and bolts to upgrade the legs of these gloveboxes could cost $80,000 each, much less $850,000. It’s not rocket science. Maybe the private corporation running the Lab underestimated the profits that they wanted to make for this much-needed work.  Make no mistake, there will be performance- based incentive award fees  for the work, as well as for the design and even the estimates.

In safety documents, the Lab originally stated that these upgrades would be done by 2011 to mitigate the possible off-site dose of plutonium to the public in the event of a large earthquake and subsequent facility fire. Guess what? The Lab will be behind schedule as well as way over budget. But LANL is already using its commitment for future glovebox seismic upgrades to reduce the mitigated dose consequence for a seismically-induced event in its dose calculations. So the public will be safe, only on paper, until the Lab finds the time and the money to upgrade those glovebox legs.

The Lab should focus on upgrading existing facilities and equipment and prove its ability and desire to protect the public before embarking on unneeded new construction, such as the CMRR – Nuclear Facility.

A Bargain – But At What Cost?

The Government Accounting Office (GAO) released a new report today. Actions Needed to Identify Total Costs of Weapons Complex Infrastructure and Research and Production Capabilities, GAO-10-582, June 2010

I’ll start with the conclusion –

Within the global community, the Administration, and Congress, a bargain is being struck on nuclear weapons policy. Internationally, if the [START] treaty is ratified, significant stockpile reductions [will] have been negotiated between the United States and Russia. Domestically, a new Nuclear Posture Review has provided an updated policy framework for the nation’s nuclear deterrent. To enable this arms reduction agenda, the Administration is requesting from Congress billions of dollars in increased investment in the nuclear security enterprise to ensure that base scientific, technical, and engineering capabilities are sufficiently supported … For its part, NNSA must accurately identify these base capabilities and determine their costs in order to adequately justify future presidential budget requests and show the effects on its programs of potential budget increases. As it now stands, NNSA may not be accurately identifying the costs of base capabilities because … NNSA cannot identify the total costs to operate and maintain essential weapons activities facilities and infrastructure, … Without taking action to identify these costs, NNSA risks being unable to identify the return on investment of planned budget increases on the health of its base capabilities or to identify opportunities for cost saving…NNSA has the opportunity to mitigate these risks by addressing them through the ongoing revision of work breakdown structures and through identifying means of collecting the total costs … Without taking these actions, NNSA will not have the management information it needs to better justify future budget requests by making its justifications more transparent. Additionally, the availability of this information will assist Congress with its oversight function. (Pg. 25)

It looks like NNSA does not know exactly the total costs of its infrastructure budget, but it does know that it wants more. The report tells us that without identifying the total costs of products and capabilities, NNSA will be challenged to explain the effects of funding changes or justify the necessity for increased investment to support or enhance base capabilities. (Pg. 25)

The reduction in nuclear warhead numbers will mean an increase spending. “In such an environment, NNSA is likely to face increased scrutiny of its planning, programming, and budget execution to determine the effect of funding increases on the overall health of base capabilities.” (Pg. 24)

Curating the Stockpile: Remanufacturing Fogbank

I only now happened to run across the article below from the Los Alamos National Laboratory Nuclear Weapons Journal about how the remanufacturing of Fogbank was reestablished. As dated as it is, I think its implication is very important that existing programs are more than sufficient to keep the nuclear weapons stockpile safe and reliable, until eventual disarmament.

You may recall that the loss of Fogbank was a bit of a crisis that seriously delayed the W76 Life Extension Program. It had at various times been used as rationale for why existing LEPs would not work in the long run because of necessary changes to materials, loss of knowledgeable workforce, etc. By extension this was used to argue why Reliable Replacement Warheads should be designed and built.

But this article demonstrates that all that was needed was to simply give some emphasis to reestablishing fogbank production. Plus as an added bonus, it has some pleasing wonky detail. “It’s the impurity, stupid!” [see link below]

LANL Nuclear Weapons Journal, Issue 2 • 2009, pp. 21-22
Fogbank: Lost Knowledge Regained

Power of the Purse over DOE Projects

I was in Washington, DC last week and heard a number of congressional offices express support for the CMRR-Nuclear Facility, indicating what we already know, that it will be very difficult to defeat directly. However, the issue of costs is another matter, and I have some hope that the Nuclear Facility can die a death of 1,000 cuts.

For example, while in DC I met with a staff person knowledgeable about DOE project cost accounting requirements introduced by the Senate Armed Services Committee. I expressed my concern that LANL could implement its first segment of CMRR-Nuclear Facility construction without having come up with total costs, thus steamrolling the project.  [Reminder: we are now $4.5 billion for estimated total project costs and climbing.]  That staffer said that sort of thing will not be allowed to happen. Further, while being in favor of some advance site prep, that staffer said LANL would not be allowed to construct the concrete batch plant and replace 225,000 cubic yards of weak volcanic ash strata with “lean concrete” until total project costs are in.

The requirements were introduced as SEC. 4713. NOTIFICATION OF COST OVERRUNS FOR CERTAIN DEPARTMENT OF ENERGY PROJECTS.

I realize this is not a showstopper, but it is something. It should slow the CMRR-NF down some, which hopefully we can capitalize on. Further, it may provide us with ammo over the project’s tremendous and escalating costs.

Nick Roth of the Alliance for Nuclear Accountability was instrumental in suggesting this cost accounting requirement to Congress.