Key Points on the Kansas City Plant Environmental Assessment

1
Key Points on the Kansas City PlantEnvironmental
Assessment

• Jay Coghlan,
• Executive Director, Nuclear Watch New Mexico
• January 2008

Please visit www.nukewatch.org for much more on
the Kansas City Plants mission and environmental
issues. In addition, there are suggested 2-page
comments on the EA and extensive notes to assist
those who want to submit comprehensive comments.
2
KCP and the Nuclear Weapons Complex
3
Turning Science into Reality
As the most comprehensive manufacturing facility
within the nuclear weapons complex, the KCP plays
an important role by taking designs from the
national labs and turning science into reality.
-Kansas City Plant website
4
Nuclear Weapons Spending and KCP

• More than 98 of the budget for the Kansas City
  Plant is nuclear weapons-related
• The yearly totals follow fluctuations in the
  overall NNSA budget (look closely to see
  non-weapons !). Sources NNSA Congressional
  Budget requests.

KCP officials state that the Plant receives
another 130 million annually in Work for
Others, but virtually all of that is for nuclear
weapons as well.
5
The Monthly Workload

• KCP claims that it is the NNSAs highest rated
  production facility.
• 5,000 nuclear weapons components packages are
  shipped monthly to other NNSA sites.
• In all, 104,000 components were shipped in 2006.

6
Pace Projected to Continue

• KCP is currently producing components for all of
  nuclear warhead types depicted above.
• KCP is currently having its heaviest workload in
  20 years.
• This pace is projected to continue until 2015.

7
Relocating the Plant
NNSA wants to build a new half billion dollar,
1.5 million square foot plant in the Kansas City
area.
8
KCP Draft Environmental Assessment

• The National Environmental Policy Act (NEPA)
  requires that proposed major federal actions be
  subject to public review.
• 97 people signed in at the May 23, 2007 public
  meeting for scoping of the EA and 24
  individuals provided oral comment, approximately
  500 individuals submitted written scoping
  comment.
• But NNSA and GSA have refused to conduct a
  public hearing on the draft EA, hiding behind a
  legal technicality that NEPA does not require
  hearings for environmental assessments in
  contrast to more rigorous environmental impact
  statements.

9
5 Points on the Draft Environmental Assessment

1. A new Kansas City Plant results in the greatest
   job loss.
2. The EA fails to address cleanup and future of the
   old plant.
3. KCP should be considered in the Nuclear Weapons
   Complex Transformation PEIS.
4. The EAs Business Case justifying a new plant
   in the Kansas City area is false.
5. Private development of a nuclear weapons plant
   circumvents congressional oversight. It also
   costs taxpayers more.

10
A New Kansas City Plant Results in the Greatest
Job Loss

• The EA proposes six different alternatives, from
  the status quo to modifications to an entirely
  new plant.
• All six alternatives include the loss of 250
  jobs.
• Local politicians who support the new plant for
  the sake of jobs are supporting the alternative
  that results in the most job loss.

11
Jobs, Jobs, Jobs
While opposing the new plant, the jobs argument
is politically the most difficult to counter.
Why cant the old plant be converted to meeting
todays needs and threats (e.g.,
nonproliferation, energy independence, etc.)?
But this is an issue for folks in Kansas City to
push hard on. To succeed, it needs local activism
and working with local politicians and
congressional delegations.
12
The EA Fails to Address Cleanup and Future Uses
of the Old Plant

• NEPA does state that connected actions must be
  analyzed together.
• There is no discussion of the fate of the old
  plant, including possible economic development
  for the Kansas City area.
• The EA excludes decontamination, demolition and
  final environmental remediation of the old Plant,
  estimated to cost 287 million.
• Cleanup at the old Plant is being deferred in
  favor of aggressive nuclear weapons production
  programs.

13
Wheres the Money for Cleanup?
Internal KCP strategic plans state that 20
million dollars in funding was needed for cleanup
in FYs 2007 2008. Despite that, and the
known presence of VOCs PCBs in soil and
groundwater, NNSA asked Congress for just 3.7
million in FYs 2007 and 2008. Should the new
plant be built, what federal agency will be
responsible for final cleanup of the old plant?
Map of contamination plumes in groundwater at KCP
-https//www.denix.osd.mil/denix/Public/Library/Re
medy/Kansas/ksplnt02.html

14
Nuclear Weapons Complex Transformation
Supplemental Programmatic Environmental Impact
Study

• What is it?
• Why does it matter?

15
2 Reasons Why DOE/NNSA did not Include KCP in the
Transformation SPEIS

• decisions regarding non-nuclear activities at
  KCP would neither significantly affect nor be
  affected by decisions regarding the
  transformation of nuclear production activities.
  (KCP EA Notice of Intent, Federal Register,
  Vol. 72, No. 83, 5/1/07)
• The Department of Energy decided to consolidate
  most activities regarding non-nuclear components
  at KCP, and therefore NNSA did not include those
  activities in the SPEIS, as it did not identify
  any programmatic alternatives for non-nuclear
  prodution sic and procurement.
  http//www.nnsa.doe.gov/docs/ComplexTrans/KCP.pdf

16
KCP Is Affected by Decisions Made Elsewhere

• For example, Los Alamos Lab has been designated
  the permanent plutonium pit manufacturing center
  and will inevitably be approved for expanded
  production.
• KCPs own position The need still exists for
  the KCP to supply non nuclear parts, tooling and
  gages for pit manufacturing at LANLpit workload
  changes have a direct effect on the KCP project
  (KCP FY07 Ten Year Site Plan)

17
KCP Should Be Considered in Nuclear Weapons
Complex Transformation

• In 1996, an alternative to consolidate KCP
  functions elsewhere was rejected because of the
  cost and environmental impacts of moving into a
  new facility.
• Now KCP is going to move to a new facility
  anyway, hence mooting that argument.
• NNSAs current proposal for Transformation of
  the nuclear weapons complex should examine
  probable benefits of integrating KCPs functions
  within Sandia Lab at Albuquerque, NM.

18
The EAs Business Case Justifying Keeping a New
Plant in Kansas City is False

• The business case assumes that since the old
  Kansas City Plant is owned by the GSA and leased
  to NNSA that an entirely new GSA-owned, 1
  million square feet plant would have to be
  built.
• The study considers only a stand-alone,
  GSA-owned plant with KCPs functions bordering
  Sandia, and not integrating those functions
  within existing Sandia capabilities and
  facilities.

19
Private Development of a Nuclear Weapons Plant
Circumvents Congressional Oversight

• NNSA proposes to have GSA build the new plant
  financed by private money. Third party
  transactions generally dont give the amount of
  federal cost obligations made over a number of
  years, and tend to avoid close congressional
  scrutiny.
• Third party transactions can cost the government
  more because of financing costs and profits to
  the private developer. Lease payments are
  projected to be over 900 million, for a 500
  million building.
• Ultimately taxpayers end up paying for all of
  this.

20
Third Party Construction Funding
(as far as we can figure out)
NNSA decides it wants a new Kansas City Plant
and asks its current landlord, the General
Services Administration (GSA), for help. GSA has
already acquired the land development rights for
NNSAs preferred location! GSA bids out
construction in a build-to-suit leasing
arrangement. The winning developer raises private
financing for construction. The private
developers lease the new plant back to GSA, and
NNSA subleases it from GSA. While the future
nuclear weapons complex is being hotly debated,
can it be possible that a new half billion dollar
Kansas City Plant will be built not subject to
overview by Congress and the power of its purse?
21
Public Comment on the Environmental Assessment
The deadline for public comment January 14
Comments and/or requests for hard copies of the
draft EA should be sent to Carlos Salazar
General Services Administration 1500 East
Bannister Road, Room 2191 (6PTA) Kansas City, MO
64131 Or, emailed to NNSA-KC_at_gsa.gov
22
Why Bother to Comment?
Because The federal government is
fast-tracking a new half-billion nuclear weapons
components plant that it refuses to hold a public
hearing for. The nuclear weaponeers want to
build up their bomb production complex, not clean
it up. Each of your comments adds to the
public record, which can help provide the basis
for resolving the issues in court. Because
democracy is a muscle. Use it or lose it!