The Secretary of Energy Advisory Board
National Ignition Facility Laser System Task Force

Members:
John P. McTague (Chairman)
Andrew Athy (Chairman, SEAB)
Robert Byer
Gail McCarthy
Lawrence Papay
Burton Richter
Rochus Vogt
John Warlaumont

c/o Betsy Mullins, Executive Director, SEAB
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585

January 12, 2000

Members of the NIF Laser System Task Force:

On behalf of the Natural Resources Defense Council, Inc. (NRDC) we are submitting written comments to the Secretary of Energy Advisory Board National Ignition Facility Laser System Task Force (herein referred to as the "SEAB NIF Task Force") in response to the January 10, 2000, Draft Interim Report. Our comments fall into the following categories: the scope of the Draft Interim report; the questions "Can the NIF be completed?" and "What does ‘completion’ mean?"; issues of prototyping and phased completion of the NIF; optics damage; amplifier glass; NIF pulsed power modules; cleanliness; and project management.

In general we find that the SEAB NIF Task Force Draft Interim Report flags serious, unresolved technical difficulties with the NIF project, but fails to answer the most useful question for Secretary Richardson, which is: "Is there a high probability that the NIF can be completed to its original performance specifications?" The Draft Interim Report’s Executive Summary states (p. ii):

The Task Force has not uncovered any technical or managerial obstacles that would prevent the completion of the NIF laser system. Nevertheless, serious challenges and hurdles remain. The NIF Task Force believes, however, that with appropriate corrective actions, a strong management team, additional funds, an extension of the schedule and recognition that NIF is, at its core, a research and development project, the NIF laser system can be completed.

While artfully worded, NRDC believes this statement is both misleading and inappropriate. Rather than attesting to its inability to uncover any obstacles that would "prevent" the completion of the NIF laser system, the SEAB Task Force should have fulfilled its charge to "review and assess the risks of successfully completing the NIF Project." While containing much useful information indicating that there are indeed substantial risks to completing the NIF Laser system, the Draft Interim Report never summarizes or attempts to quantify these risks, much less the overall technical risks of "successfully completing" the "NIF Project" as a whole, including achievement of fusion ignition.

Moreover, the assessment that the Task Force has uncovered nothing that would "prevent" completion of the NIF laser system is a virtually meaningless statement. One could make the identical statement about a proposal to build a huge collector on the Mall to generate electricity from moonlight, but that doesn’t mean it would be cost effective or sensible to build such a facility.

The Task Force’s seemingly pithy conclusions actually beg the most important questions:

1. What is it likely to cost to reach the various projected levels of capability for the NIF Project, up to and including achievement of its original design specifications for fusion ignition, and what is the technical risk that these performance levels will either not be attained or delayed significantly?
2. What is the impact on the cost-effectiveness of the public investment in NIF if it is constrained to operate indefinitely at levels far below those needed for an extended campaign of shots needed to achieve fusion target ignition?
3. Is it worthwhile to continue the project if the most likely result is a facility constrained to operate at 400-800 kilojoules (kJ), rather than 1.8 megajoules (MJ)?

Next, we have the Task Force’s astonishing statement that with more dollars -- no amounts are specified -- further corrective actions, management changes, schedule stretchout, and a "recognition that that NIF is, at its core, a research and development project," the NIF laser system "can be completed." First of all, the NIF is NOT an R&D project, and arguably hasn’t been since FY 1995, when it entered the detailed engineering design phase, and clearly since June 1997, when facility construction began. NIF is a DOE "Major System Acquisition," not an "R&D Project."

Second, it would be inappropriate for the SEAB, explicitly or implicitly, to endorse the Draft Interim Report’s conclusions without first acquiring an understanding of the relative costs and risks involved in completing the project at the various projected levels of capability. One can envision all sorts of projects that "can be completed." The essence of analysis is to determine whether a project can be completed and operated at its design specs and at an acceptable cost that is commensurate with the importance of its mission, and with an acceptable degree of technical risk.

On the first page of the Draft Interim Report, a document referred to as the "Emmett Report" is given first citation among "the work of previous review panels and advisory boards" utilized by the SEAB NIF Task Force. The Emmett Report is the November 4, 1999 report by the Technology Review Group of the NIF Council, chaired by Dr. John L. Emmett. Furthermore, the SEAB NIF Task Force recommended in its response to Finding V (p. v) that the DOE "Consider and respond appropriately to the thoughtful recommendations of the Technology Resource Group of Lawrence Livermore’s NIF Council (the Emmett Group)." In some cases, the SEAB NIF Task Force echoes the November 4, 1999 findings of the Emmett Group, but in many instances those findings were not reported and are more broadly troubling than information provided in the SEAB NIF Task Force Draft Interim Report.

For example, the Emmett Report observes that the "technology development budget appears to have been exhausted by the end of fiscal 1998 with much work remaining if the NIF goals are to be achieved." (p. 5) And further: "By the end of fiscal 1998, many of the technology development efforts were terminated because of budget pressures, although much work remains to be done and a few specific performance goals are yet quite distant. In addition, much fundamental science, scientific measurement capability, and numerical modeling activity, was hardly supported or never engaged at all, even though these activities are key, in our estimation, to the overall success of the NIF Project." (p. 6) These observations are clearly central to a discussion of current failings with the NIF management and project execution thus far, and to providing guidance on the substantial research and development which lies ahead for the NIF project, yet were never addressed in the SEAB NIF Task Force Draft Interim Report. In the course of these comments NRDC will reiterate findings of the Emmett Group, where appropriate, in response to the SEAB NIF Task Force Draft Interim Report.

Scope of the Interim Report

1. The Draft Interim Report states (p. 2) that "at this time it is premature to make final recommendations on some of the recent changes adopted and those currently under consideration by the Department and the lab to address the problems facing the NIF project." This being the case, we submit that it is likewise premature for the Task Force’s Interim Report to be rendering a conclusion that completing the NIF laser system is feasible and desirable, and advocating increases in NIF research and development funding. Moreover, it is highly inappropriate for the Interim Report to rely selectively on certain aspects of the proposed NIF "rebaselining proposal" without disclosing the full dimensions of this proposal, especially as they affect the ultimate cost, schedule, and capabilities of the finished project.

2. In the Section "Project Planning and Rebaselining" (p. 10), the Draft Interim Report relies on aspects of a "rebaselining plan" -- such as a proposed beam commissioning schedule -- without disclosing the complete outlines of this plan or the increased costs involved. While possibly unintended, this is a manipulative and intellectually dishonest way to proceed, and the full SEAB should not endorse this partial "phased disclosure" of the changes that have been proposed in the NIF project.

3. The Draft Interim Report states (p. 3) that NIF was designed to produce, for the first time in a laboratory setting, "conditions of matter close to those that exist at the center of stars and inside detonating nuclear weapons. DOE plans to use this facility for physics experiments to increase understanding of the performance of nuclear weapons without further need for nuclear testing." Not only is this statement misleading (or at best, incomplete), but issues relating to the justification of NIF and the physics of planned research were supposed to be excluded from the scope of the SEAB NIF Task Force’s study.

While the NIF team has made much of its plot of temperature versus pressure phase space that shows the NIF significantly overlapping the weapons regime, in fact the relevant parameter is not temperature (T) but radiation flux, which is proportional to T4. So a NIF hohlraum driven to 300 eV may look like it’s a factor of 4-7 away from weapons, when in reality it is a factor of 250-2400 away from the weapons regime -- three orders of magnitude! Then one must consider that NIF hohlraums are probably unsuitable for well-characterized equation-of-state (EOS), opacity, and most hydrodynamic experiments because of a significant non-local-thermodynamic (non-LTE) component to their x-ray spectra (i.e., line radiation above 1 keV in energy). This indicates that such weapons experiments are more likely to be performed in a high-power, short-pulse, direct-drive regime, calling into question the entire rationale for NIF if ignition has receded as the principle objective of the project.

4. The Draft Interim Report (p. 3) cites a DOE document (the "30-Day Review") to the effect that "NIF is one of the most vital facilities in the stockpile stewardship program." In fairness, the Interim Report should indicate that many experts both inside and outside the DOE weapons complex emphatically do not agree with this statement, and assign a priority to NIF that is far below, for example, enhanced stockpile surveillance, stockpile refurbishment, ASCII, hydrotesting, and materials science.

Can NIF be completed? What does ‘completion’ mean? Is the NIF a research and development project or a major systems acquisition?

5. The Draft Interim Report states: "NIF is a research and development project aimed at achieving ignition of a deuterium-tritium (DT) fueled sphere by laser induced inertial confinement." (p. 25) As previously noted, the Task Force is unilaterally rewriting DOE’s and OMB’s system acquisition regulations! At the present juncture, NIF is a DOE Major System Acquisition entering its third year of physical construction! The Task Force’s attempt to subtly recast this major facility acquisition as a neodymium glass (Nd:glass) laser research and development (R&D) program is misdirected and dishonest. If the Task Force is in fact proposing that the NIF Project be restructured to become an Nd:glass laser research program, then why simultaneously press ahead with the construction project? The Task Force cannot have it both ways, at least not without a much more extensive and explicit exposition of the rationale for its position.

6. The Draft Interim Report implicitly equates completion of NIF Laser construction to degraded (3 J/cm²) fluence specifications with successful "completion" of the NIF Project as a whole. This sidesteps many of the most important technical obstacles to "success" of the project and ducks entirely the issue of primary importance to the Secretary, Congress, and the public, namely the probable cost effectiveness of NIF for achieving science-based stockpile stewardship and fusion ignition objectives in light of the now reduced expectations for laser performance, its hugely escalating costs, and large unfilled gaps in beamline diagnostics and control, target fabrication, target positioning, and target assembly diagnostic capabilities.

7. The report does not offer a clear distinction between the requirements for NIF laser system completion on the one hand, and the requirements for NIF to operate at the total energy, power pulse shape, frequency, beam uniformity, focused spot size, beam-to-beam power balance, etc. needed to meet its mission of demonstrating thermonuclear ignition in the laboratory. Without any explicit acknowledgment by the Committee, what was once billed as a "reasonably confident" project to achieve fusion ignition in the laboratory at 1.8MJ has now been reduced to building a laser system that will be constrained to operate at considerably less than 0.9MJ -- insufficient for ignition -- when and if it is completed in 2008, five years late with a cost overrun that likely will exceed a billion dollars.

8. The Draft Interim Report’s recommendation (p. v) that "the NIF project management and project controls systems should clearly establish the point at which construction and testing ends and NIF operations begins," is at variance with its (mistaken) conception of NIF as a continuing R&D project and with its endorsement elsewhere of a "phased deployment" strategy involving more or less simultaneous operation of an initial beam bundle(s) while constructing the remainder and conducting continuing R&D to improve optics damage thresholds. Likewise, the Task Forces reports elsewhere that beam control diagnostics and small optics lag far behind and will have to be further developed, tested and integrated even as the initial beamlines are constructed and "operated," further blurring what has become an utterly indecipherable line between "construction and testing" and "NIF operations."

9. The Draft Interim Report states (p. 13): "The NIF project is badly over budget and one and one-half to two years behind schedule. " This statement is so misleading that it must be judged to be factually incorrect. If the original baseline was 192 beams by the end of 2003, then the project is minimally five years, not two years, behind schedule. If the benchmark is the date at which the project could begin conducting ignition experiments with the prerequisite beam energy, beam control, ignition targets, and diagnostics in place, then completion of the project must be assessed as "indefinitely delayed." If mission success -- i.e., achievement of ignition -- is the criterion, then the project must be considered not merely "behind schedule," but without a schedule.

Prototyping of the NIF

10. The Draft Interim Report does not adequately or accurately describe what was, and was not established by the NIF prototyping efforts. There were two main experimental prototyping efforts conducted by Livermore for the NIF project: Beamlet and Amplab. Beamlet tested a complete beamline with the same optical arrangement planned for the NIF but with different hardware, and was completed in 1994. Amplab consisted of a full-scale 4x2 amplifier bundle which was three slabs long rather than the eleven planned for the main amplifier bundles on NIF. The NIF amplifiers are massive, precise optical components which essentially determine the characteristics of the beam prior to its frequency tripling. Amplab was a joint project of Livermore and the French nuclear weapons program (CEA), and full-scale testing began in 1997. Significantly, Beamlet and Amplab were terminated at a point where experimental difficulties with the NIF design were apparent, but before these problems could be well understood or solved.

With respect to prototyping the NIF, the Emmett Report notes (p. 6): "The NIF Project Plan did not include the construction of a prototype which would have been used to test the various components and technologies, to evaluate alignment and diagnostic procedures, and to work out the assembly methodology in advance of NIF installation."

11. The Amplab prototype amplifier was designed, built and tested, but, according to the Emmett Report (p. 12), "only a limited subset of . . . objectives were achieved." The amplifier gain (percent increase in energy per unit length) measured at Amplab was 5.1±0.1 %/cm under optimum conditions, whereas the NIF spec is 5.0%/cm during system operation. The Emmett Report observes (p. 12): "it is not clear that there is any gain margin under the most optimum conditions, and that if there is any gain margin at all, the water in real NIF glass will eliminate it. In addition, it is quite obvious that the required gain cannot be maintained in the presence of normal degradation during system operation." The Emmett Report clearly states that: (1) not all of the necessary research in preparation for construction of the NIF amplifiers was performed at Amplab, particularly in the area of optical distortions; and (2) the results that were obtained indicated that NIF specs could not be met. Despite the lack of adequate prototyping data to inform NIF construction, the Amplab experimental campaign was terminated.

12. The Draft Interim Report states (p. 19): "Issues related to the laser architecture, laser gain, energy extraction, beam shaping, temporal pulse shaping, and nonlinear frequency conversion were addressed by experiments and operating experience on the NOVA and the Beamlet laser systems at Lawrence Livermore lab." These issues may have been "addressed" -- whatever that is supposed to mean -- but they were far from solved. As we have previously pointed out to the Task Force, Beamlet never demonstrated the necessary fluence appropriate to a 1.8 MJ NIF while simultaneously using one-third micron light, the cheaper glass, a wider NIF spatial filter aperture, beam focusing, and measurements of time dependent imaging from the pinhole. The reluctance of the Task Force to be explicit and clear about this matter could be seen by some as an attempt to mislead the Secretary and the public.

13. On page 19 the Draft Interim Report states: "Experiments on the Beamlet laser at Lawrence Livermore lab . . ." Again, same issue as in #12 above. This is not a fair and balanced description of what Beamlet did and did not demonstrate. This issues needs a more complete and forthright discussion.

14. From a March 1998 Livermore publication, it may be inferred that the decision not to emphasize experimental prototyping is a program-wide attempt to save money which may ultimately backfire (Howard T. Powell and Richard H. Sawiki, "Keeping Laser Development on Target for the National Ignition Facility," Science and Technology Review, March 1998, p. 5):

Cost-cutting efforts rely increasingly on computer-aided design. "When we built Nova, the designers used pencil and paper and built a lot of full-scale models," notes [NIF Associate Project Engineer Richard H.] Sawiki. In contrast, NIF parts are designed and scrutinized on computer by a team of a hundred designers using the latest three-dimensional engineering software. Even entire systems, on the scale of hundreds of meters, are modeled on computers to make sure there is adequate room to move equipment in and out.

In addition, we would emphasize that at present it is pragmatically necessary to do non-linear optics experimentally, whereas the NIF project has clearly relied too heavily on numerical simulation and theory for key project decisions.

Phased Construction of the NIF

15. The recommendation (p. vi) that the "original NIF performance goals should be maintained, but reached in a phased manner" is sensible in principle, but meaningless in practice, as the Draft Interim Report provides no basis for assessing whether NIF’s original performance goals remain fiscally and technically reasonable. Moreover, the Task Force’s conception of a phased implementation is never developed into a practical proposal, and remains extremely unclear.

16. The Draft Interim Report notes (p. 15) that "the entire infrastructure for all 24 bundles will be completed before the optics for the first bundle is installed," and correctly observes that "such a plan greatly increases the difficulty of incorporating operational learning experience from the first bundle into the infrastructure design." The Task Force further observes that "the assembly plan relies on process control without direct measurement of final assembly cleanliness, thereby precluding a guarantee of satisfactory assembly…This challenge is exacerbated by the absence of a NIF bundle prototype which adequately addressed assembly and cleanliness issues."

Given these views, one would logically expect the Interim Report to recommend successful clean assembly and operation of the first beam bundle (or one beamline with associated shared bundle equipment) as the sine qua non for proceeding with the project. On the contrary, the Task Force inexplicably concludes, "NIF is being constructed without adequate prototyping, but it is not appropriate to halt further work to construct a prototype." Given all the interdependent technical challenges the Task Force itself has just enumerated, and the existence of other potentially crippling issues that the Task Force has chosen to ignore, WHY DOESN’T IT MAKE SENSE TO HALT FURTHER WORK AND BUILD AND TEST A HIGH FIDELITY BEAMLINE PROTOTYPE that integrates and successfully demonstrates all the performance parameters and equipment needed to build the 96 or 192 beam system and operate at the design parameters deemed necessary for ignition? The Draft Interim Report completely begs the answer to this obviously simple and vital question.

The Draft Interim Report under Finding VII calls for a phased implementation of the NIF project. Under Finding VII "[t]he Task Force proposes that key milestones be established to clearly delineate the transition between the various phases . . ." Also, in the body of the report the Task Force concludes, "Major projects within the laboratory must also have clearly defined deliverables and goals, with adequate measurement tools for progress . . ." The Interim Report should include a recommendation that the transition to a following phase be conditioned on demonstrating clearly defined deliverables at the completion of each phase. For example, we believe the NIF project should not be permitted to construct 96 beams (12 bundles) until the project can demonstrate it can operate 8 beams (one bundle) simultaneously meeting all design criteria related to ignition, e.g., total energy, power pulse shape, frequency, beam uniformity, focused spot size, beam-to-beam power balance, etc. Similarly, before completing a single bundle, the same demonstrated should be required of a single beam line with the exception of beam-to-beam power balance.

Optics Damage

17. The Draft Interim Report provides no evidence for its finding (p. vi) that the achievement of "full fluence in the FY 2007 time frame" is, "with appropriate research and development . . . a reasonable projection." On the contrary, a close reading of the Emmett Group’s report most obviously leads to the opposite conclusion -- that there is no technical basis today for believing that full fluence can be achieved, or for predicting what the costs of the R&D and retrofit program will be.

18. The Draft Interim Report suggests that a pause after deployment of the first 96 beams is desirable, and that this conclusion is "especially true" if the NIF Council’s Technology Resource Group’s "concerns about the need for advanced materials turns out to be justified." This reference is needlessly cryptic, and should be further explained, as we do in paragraph 20 below. Is the Task Force suggesting that an entirely new optical material(s), as yet uninvented, will be required to increase NIF’s damage threshold sufficiently to permit ignition experiments? What are the implications for the project if these new materials are not forthcoming?

19. The Emmett Report in its concluding emphasis states that (p. 3): "Today’s damage and materials status should permit reliable operation at 3 J/cm². If these recommendations are pursued aggressively, operations at 4-5 J/cm² in Phase 1 could be projected. With continued work, operation at 8-9 J/cm² in Phase 2 will become realistic." These findings would imply the following total energy for the following NIF options:

The argument has been made that nuclear weapons experiments planned for the NIF can be performed with the energy available from the first 96 beams. In particular, such experiments do not require the full symmetry provided by illumination from 192 beams. From the Emmett Report it is clear that aggressive R&D for 96 beams will produce only 25 percent less energy than 192 beams at today’s optical damage threshold. If work beyond aggressive R&D is successful on 96 beams, the same energy can be produced as for 192 beams with aggressive R&D. Given the unknown changes to construction and procurement which aggressive or "continued work" beyond aggressive R&D would entail, this would indicate that a significant pause at 96 beams is warranted pending further research on optical damage. Importantly, the NIF energies required for ignition can only be obtained through successful "continued work" beyond aggressive R&D to increase optical damage thresholds. The success of NIF requires the achievement of a fluence of 8-9 J/cm², but the Emmett Report claims that the project did not back up that requirement with the R&D program necessary to achieve it.

20. The Emmett Report notes (p. 16): "the majority of optical damage problems faced in the development of the NIF system are associated with the optical components that are exposed to the 3 omega (i.e., frequency tripled) beam." These optical components for each of the 192 NIF beamlines are the second of the two DKDP nonlinear optical crystals, the fused silica diffractive optics, the focusing lens, and the debris shield. Each of these optical components are coated with anti-reflective coatings, and they are all contained in the Final Optics Assembly (FOA) which is under vacuum. The Emmett Report states (p. 17):

Most of the NOVA 3 omega optics are operating in air, while all of the NIF 3 omega optics operate in a vacuum in the FOA. About a year ago in Beamlet experiments it was discovered that high fluence 3 omega damage on surfaces in a vacuum was catastrophic; that is, it is not self-limiting but grows rapidly in extent with each successive laser pulse. In addition it was discovered that, in a vacuum, particles that are ejected from the surface (as a result of 3 omega damage) also damaged other nearby facing surfaces. In the current NIF FOA design, all of the optics are very closely spaced, which means that damage to one surface will propagate to the next facing surface.

These conclusions are dramatic, and the Emmett Report recommends a return to very basic research and development in materials science, which is very far removed from construction/engineering type activities. A measure of this is the following statement in the Emmett Report (p. 20): "The type of catastrophic damage being observed on fused silica at high fluence in a vacuum fundamentally calls into question whether fused silica can ever go the distance to reliable operation at full NIF fluence or above." If there is some uncertainty as to whether fused silica components can be used in the FOA, this will certainly impact procurement decisions! According to the Emmett Report the debris shield is also a serious NIF materials problem (p. 21): "At present it is a coated fused silica plate at the highest 3 omega fluence point in the system, and has to operate in vacuum with some amount of target debris on one surface. At the present time it is unlikely that it would survive more than several shots at full NIF fluence before mandatory replacement, and they are not cheap."

NIF Amplifier Glass

21. With respect to amplifier glass manufacture, the Emmett Report states (p. 11): "While tests and analysis indicate that the NIF OH spec of <2 cm^-1 can potentially be achieved, we believe it may be an unrealistic expectation. It would seem to us that OH absorption of 2-4 cm^-1 is more realistic. Thus we would recommend that the additional capacitors be incorporated in the NIF amplifier capacitor banks to compensate for the lower resulting gain."

Pulsed Power Conditioning Modules

22. The Draft Interim Report fails to address the implications of recent failures of the Pulsed-Power Conditioning Modules (PCMs). Sandia National Laboratories had responsibility to develop the prototype 1.7-2.1 MJ PCMs that will power the NIF’s flashlamps in the main and power amplifiers. The First Article NIF Test Module (FANTM), was built at Sandia and operated between October 1998 and May 1999 for a total of about 17,000 shots. Over the course of this time three dramatic capacitor failures resulting in explosions occurred, and several non-dramatic capacitor failures occurred. Estimates of the shot-to-shot reliability of the NIF indicate 1 capacitor failure out of 192 modules for every 10th shot.

The violence of the explosions in the case of dramatic capacitor failure reportedly came as some surprise. The PCS modules had to be redesigned with shielding to contain debris and damp shock waves produced in explosions, which are expected to occur regularly in NIF operation (more than once a week for a shot rate of three per day). The original NIF design, however, had the PCS modules so closely spaced that building in additional shielding left no room for servicing the modules. Consequently, the PCS modules, which weight approximately 8 tons each, were redesigned to be movable so that they could be extracted from their positions in the capacitor bay and removed for servicing. These engineering changes have resulted in increased cost to the NIF. In addition, the expected, regular occurrence of sizable explosions in the capacitor bay has created additional risk to other components and personnel which has not been completely mitigated by current design changes.

To date all of Livermore’s potential bidders for constructing the NIF PCS have withdrawn their bids because of concerns over liability for capacitor explosions.

Cleanliness

23. The Draft Interim Report states (p. 17): ". . . beampath integration and the achievement of adequate cleanliness are not predicted to be factors in preventing NIF from meeting its performance objectives." The technical basis for this statement is by no means clear, and most thoughtful observers would regard such a conclusion at this stage as being quite rash and ill considered. It is also inconsistent with the earlier finding on page 15 that "a guarantee of satisfactory assembly" is "precluded" by the assembly plan’s reliance on "process control" rather than "direct measurement of final assembly cleanliness," and with the observation on page 21 that "the formation of particles on the surfaces of the NIF beamline optics is a concern as particles are the initiation sites for optical damage. Since cleanliness is intimately related to the initiation and subsequent propagation of optical damage, and optical damage surely is a factor "in preventing NIF from meeting its performance objectives," the Draft Interim Report in this instance verges on incoherence.

Project Management

24. The Draft Interim Report states, (p. 5) "No independent expert who understood NIF’s huge stretch in performance requirements beyond any previous experience with high power lasers would have accepted a 15% overall contingency on the project." NOT TRUE! As already shown in detail to the Task Force (See NRDC’s 12/14/99 Memorandum to the Secretary and the Task Force, pp. 12-13) the 1996-97 National Academy Panel, which included Task Force member Robert Byer, examined the contingency problem and deemed it acceptable.

25. The Draft Interim Report fails to deal forthrightly with the fact that senior officials of LLNL misled and induced the Secretary of Energy to declare to Congress and the press that the NIF Project was "on schedule and on budget." It fails to assign responsibility for this reprehensible conduct, or to recommend disciplinary actions against those responsible. Instead, we are told merely that another panel, chartered by the labs management contractor, the University of California, had uncovered a "do-it-yourself" mentality in the laboratory that led to "denial and delays in correcting problems." Not exactly a "Profiles in Courage" performance by either panel.

Conclusions and Recommendations

In conclusion, the current NIF Task Force Report begs many important questions and is manifestly vague, misleading, contradictory or incomplete on a number of important points. If it goes forward in its present form, with only minor editing, NRDC will urge SEAB to withhold its assent to the report, or alternatively, forward it to the Secretary with the clear caveat from SEAB that it does not reflect the views of the full Advisory Board, not least because it fails to comply with the Secretary’s charge "to review and assess the risks of successfully completing the NIF Project."

While a careful reading of the substantive technical findings in the Task Force’s Draft Interim Report easily justifies the conclusion that these risks are very substantial, and possibly even crippling, this judgment is nowhere explicitly stated, quantified, or even qualitatively assessed in the report. On the contrary, subtly but insistently, the Draft Interim Report inexplicably tends toward the opposite conclusion, that these risks are acceptable despite a lack of firm knowledge regarding the project’s ultimate capability and costs.

The Task Force seems to be responding to some hidden categorical imperative to proceed with the NIF Project that is never explicitly stated, but perhaps hinted at when the Draft Interim Report states (p. iv): "The success of the NIF is vital to the future of the entire Lawrence Livermore Laboratory, both programmatically and in the lab’s ability to continue to attract and retain the best and brightest technical people." This too must be regarded as an unsubstantiated assertion, and one that many scientists even at Livermore do not agree with. On the contrary, many Livermore scientists fear that NIF’s funding demands are already excessive and crowding out other important scientific and engineering projects at the laboratory.

Moreover, elsewhere the report states "Issues such as weapons justification, . . . were beyond the scope of the Task Force." (p. 1) Since (a) weapons justification issues were not addressed by the Task Force, (b) the Draft Interim Report provides no support for the claim that " the success of NIF is vital . . .," and (c) the claim is disputed by critics of the NIF, both in and outside the program, the statement should be deleted from the report.

Finally, the SEAB or any of its subpanels should not be placed in the "patsy" position of recommending a vague "continuation" of the NIF Project without first obtaining a complete analysis and understanding of the full costs and schedules required to complete the NIF Project in line with its stated design objectives. NRDC strongly suspects that these costs are unacceptably high, and if accepted, are likely to result in the acquisition of a substantially degraded product from that originally advertised by its promoters.

Sincerely,