June 2, 2020
Ms. Jennifer Nelson
NEPA Document Manager
NNSA Savannah River Site Field Office
P.O. Box A
Aiken, SC 29802
Email to: This email address is being protected from spambots. You need JavaScript enabled to view it.
Re: Scoping comments for the National Nuclear Security Administration’s (NNSA’s) draftEnvironmental Impact Statement for plutonium “pit” production – for unjustified nuclear weapons - at the proposed Plutonium Bomb Plant at the Savannah River Site
Dear SRS EIS NEPA Document Manager,
Citizen Action New Mexico (CANM), an Albuquerque 501 (c)(3) sponsored organization, submits these comments as provided for by the National Environmental Policy Act (NEPA) on the scope of issues that the NNSA must address in its draft environmental impact statement for plutonium pit production in the proposed Plutonium Bomb Plant (PBP) at the Savannah River Site (SRS). CANMalso looks forward to submitting comments on the draft EISafter its completion.
"A humanitarian is a man who believes that no human being should be sacrificed to a project –- especially to the project of perfecting nuclear weapons to kill hundreds of millions of people."
Albert Schweitzer. "A Nobel scientist speaks: Every test kills..." Liberation (New York) 2, no. 11. February 1958.
Shortly after the atomic bombs were exploded over Hiroshima and Nagasaki1, Albert Einstein made this statement: “The time has come now, when man must give up war. It is no longer rational to solve international problems by resorting to war.
IT IS OBVIOUS THAT THE DOE/NNSA AND U.S. GOVERNMENT ARE EMBARKING ON AN IRRATIONAL PLAN TO CONSTRUCT MORE NUCLEAR WEAPONS:
- WITH THE SOCIAL INSTABILITY OF THE PANDEMIC COVID-19,
- WIDESPREAD RIOTING ACROSS THE U.S.,
- THE EXTREME FINANCIAL NEED OF 40,000,000 PEOPLE OUT OF WORK,
- INCREASE IN THE NATIONAL DEBT BY TRILLIONS OF DOLLARS,
- INCREASED DANGER OF A NEW ARMS RACE AND PROLIFERATION,
- CREATION OF UNNECESSARY WEAPONS OF MASS DESTRUCTION FOR THE PLANET AND ITS PEOPLES
- INABILITY TO DISPOSE OF THE NUCLEAR WASTES FROM PAST AND PROPOSED PRODUCTION,
- RISK OF NUCLEAR WINTER AND EXTINCTION,
- AND A PSYCHOTIC AND DANGEROUS PRESIDENT.
The nuclear weapons industry already has produced tens of thousands of nuclear weapons that are useless for defense and would lead to destruction of large portions of the planet we all share if used.At least 5,000 nuclear weapons are currently deployable by the US. Why the hell do we need any more? The legacy wastes from nuclear weapons production have produced a nightmare of cancer for workers and surrounding communities wherever nuclear weapons production has taken place. Billions of dollars annularly are spent on worker and downwinder cancer and disease from past legacy production and contamination. That contamination will continue to increase and adversely impact Savannah River as well as other communities across the US that become involved with contributing facilities andas related activities continue to be expanded.
The Aiken Standard recently reports radioactive contaminated water from the SRS site. https://www.aikenstandard.com/news/radiation-contaminated-water-discovered-at-srs-facility-new-report-states/article_df8fab38-1a7f-11e9-8ebc-9b1b2832b0b2.html The Savannah River is already contaminated as a result of SRS operations and there is no cleanup in sight. No further SRS operations should continue.
The NNSA is among the most irresponsible, wasteful, incompetent, deceiving, evil organizations on the face of the planet; is totally incompetent to carry out any nuclear project without mind boggling devastation to a community’s populace;creating the worst environmental contamination that is never adequately remediated; and will exist for millennia if not millions of years. NNSA operations will guarantee more damage to Americans than any foreign enemy is causing.
The history of nuclear weapon production facilities throughout the United States as a major component of environmental damage and human injuries demands nothing less than a full appraisal of a Programmatic EIS in relation to any continuing or expanded pit production.Waste handling operations of the DOE/NNSA at present, let alone for future operations are without coordination, viable locations or well considered plans. The reprehensible record in New Mexico for worker injuries, cancer, fires, explosions, Rio Grande River and groundwater aquifer contamination from Los Alamos Laboratories (hexavalent Chromium plume), Sandia National Laboratories (Mixed Waste Landfill dump), and WIPP (fires, explosions, plutonium cloud)alone will attest to that, but add in for good measure Hanford, WA (Columbia River contamination) ,the Idaho National Laboratories, ID (Snake River contamination) and the radioactive waste cloud sent over four states from metallic sodium explosions at Beatty NV. The handling of plutonium and radioactive materials and waste at existing facilities has been dangerous and resulted in numerous accidents due to human error, lack of training and inadequate facilities. The track record of the nuclear weapons industry is abysmal with respect to any aspect of its production for the public and environment – air, water and soil.
Nuclear weapon production is not a defensive tactic for the US because it results in heightened international anxiety and insecurity in other nations that proceed to increase production of nuclear weapons or materials to produce them, with N. Korea and Iran being two examples. The pit production ramp up is nothing more than a boondoggle for corporations that want to crank up a new arms race to benefit their profit margins.
Criticality Safety: There is insufficient staffing of fully-qualified and experienced criticality safety engineers to support the site’s current and planned fissile material operations.
Especially given that pit fabrication would be totally new to SRS and would be for unjustified new nuclear weapons, CANM supports the “No Action Alternative” of not “repurposing” the failed MOX Fuel Fabrication Facility (MFFF) for conversion into the plutonium Bomb Plant.
No demonstrated need for additional plutonium pit production:A recent review by JASON of an evaluation of plutonium pit lifetimes by the Laboratories, and accepted by the DOE/NNSA, concludes, “The assessment demonstrates that there is no degradation in performance of primaries of stockpile systems due to plutonium aging that would be a cause for near-term concern regarding their safety and reliability.
Most primary types have credible minimum lifetimes in excess of 100 years as regards aging of plutonium; those with assessed minimum lifetimes of 100 years or less have clear mitigation paths that are proposed and/or being
implemented.”
The Draft EIS must analyze the impacts of diverting taxpayer dollars to new nuclear weapons facilities instead of keeping the focus on the cleaning up the massive environmental damage caused by past nuclear materials production and other waste-producing activities at SRSand across the United States.The public health and environmentaleffects of new radioactive and chemical waste streams that can result in health impacts and pollute precious water resources must be fully reviewed.
- NNSA is likely to throw bad money after bad after 7 billion taxpayer dollars were wasted on the canceled MOX Facility. At the same time independent studies have called NNSA’s plan to repurpose the MFFF “extremely challenging” and impossible to achieve by 2030 as claimed. It appears that NNSA’s rush to proceed with the Plutonium Bomb Plant will be rife with massive cost overruns and endless schedule delays, as we saw with the MOX boondoggle.
- NNSA’s Fiscal Year 2020 budget request and other documents make clear that future pit production will not be to maintain the safety and reliability of the existing nuclear weapons stockpile. Instead future production will be for modified pit designs for new-design nuclear weapons, which has negative nuclear non-proliferation implications. Given the current moratorium on explosive testing of nuclear weapons, those pits cannot be full-scale tested or alternatively, could prompt the U.S. to return to testing, which would have serious international proliferation consequences.
- Some 15,000 or more plutonium pits already exist and are stored at DOE’s Pantex site in Texas. Independent experts have concluded that modern pits have reliable lifetimes of a century or more. Given this, the draft SRS EIS needs to fully and concretely justify expanded plutonium pit production and discuss reuse of stored pits.
These matters must be considered in a nation-wide programmatic environmental impact statement (PEIS) to be conducted by DOE, a document that must precede the draft SRS EIS. That PEIS is required to raise the current 20 pits per year production cap set by the 1996 Stockpile Stewardship and Management PEIS, which authorizes pit production at only the Los Alamos Lab in New Mexico. A new PEIS is made further necessary now that NNSA plans to have production at a second site (at SRS).
The draft SRS EIS Must Be Completely Free of Predetermination.
Thisdraft SRS EIS will beclearly unusual given that the MFFFis alreadypartially built. NNSA must concretely demonstrate that it can pursue an impartial process without predetermination that leads to an objectivedecision to repurpose the MFFF, which is faced with design problems and construction problems,for pit production or not.
SRS must not be considered for pit production just because the MFFF already exists.
The issue of jobs or contracts must not drive the establishment of plutonium pit production at SRS, but that appears to be a main motivator for DOE and local politicians and contractors with financial interest in the matter. Those issues should have no bearing on a national security program of this sort. Making this project into a parochial jobs project is also part of DOE’s recipe for failure.
Before repurposing of the bungled MOX Plant is even considered, there should beinvestigations into fraud, waste, abuse and mismanagement associated with the MOX program both before and during its termination.
What are the risks of establishing plutonium pit production at SRS, which will be a completely new mission there? Will staff be adequately trained? Will SRS avoid the chronic nuclear safety problems that have plagued the Los Alamos Lab, which has 70years of experience in pit production yet can still not carry out that mission?
The risks of transport of plutonium back and forth to SRS from such sites as the PantexPlant in Texas and the Los Alamos Lab must be analyzed in the draft EIS.
The draft EIS needs to disclose all radioactive and toxicwaste streams and howthey will be disposed of. The State of South Carolina has been in a long legal struggle with the Department of Energy to not become the nation’s de facto dumping ground for excess plutonium. How will expanded pit production add to the unwanted inventory of 12 metric tons of plutonium that is already at SRS? If pit production were to get underway and then stop, what guarantee is there that more plutonium would not be stranded at SRS?
All analyses in the draft EIS must address the health risk of waste streams and plutonium management (including criticality risks) to the most vulnerable, that is topregnant women, fetuses, children and the elderly, rather than the standard, less vulnerable “Reference Man.”
All draft SRS EIS reference documents must be made accessible online.
The plan to produce more plutonium pits at SRS is a monumental financial scam of the military/industrial complex and an assault on the safety of the peoples of the world and the earth we inhabit.
Sincerely,
David B. McCoy, J.D., Executive Director
Citizen Action New Mexico
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