1. Key Points on the Kansas City Plant Environmental 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 1.…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) 2.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 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 LANL…pit 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 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? (as far as we can figure out)

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@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!