PLEASE SUBMIT COMMENTS BY JULY 14, 2025ON ENVIRONMENTAL REVIEW OF NEW PLUTONIUM BOMB FACTORIES
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July xx, 2025 (use today’s date; last day to submit comments is July 14 so submit by then)
Ms. Jade Fortiner
NEPA Document Manager
National Nuclear Security Administration
Office of Pit Production Modernization
U.S. Department of Energy
1000 Independence Ave. SW
Washington, DC 20585
Scoping Comments on NNSA’s “Notice of Intent To Prepare a Programmatic Environmental Impact Statement for Plutonium Pit Production,” of May 9, 2025
(https://www.govinfo.gov/content/pkg/FR-2025-05-09/pdf/2025-08140.pdf)
I hereby submit the following comments to inform the “scope” of a draft plutonium pit-production Programmatic Environmental Impact Statement (PEIS).
I request that the matters below be addressed in detail in the draft PEIS that is to be released by DOE’s National Nuclear Security Administration (NNSA) in 2026. The PEIS was required of NNSA after a federal court victory by public interest groups and resultant settlement between those groups and NNSA.
I further request that my name be added to the PEIS mailing list and that I be given opportunity to comment on the draft PEIS.
The “No Action Alternative” in the draft PEIS must be disarmament and not production of new plutonium pits for new warheads. The Nuclear Nonproliferation Treaty (NPT), to which the US is a signatory, requires parties to the treaty “to pursue negotiations in good faith on effective measures relating to cessation of the nuclear arms race at an early date and to nuclear disarmament…” The NPT is not only US policy but is also law. Production of new warheads using new plutonium pits runs counter to the NPT and will contribute to a budding nuclear arms race.
Why SRS, an improbable site as it has no pit handling or production experience and little plutonium-processing experience, was chosen in 2018 as a pit-production site must be reviewed. There will be a host of challenges at SRS due to its lack of expertise with pit production, including casting liquid plutonium to exacting standards into the hollow spheres that constitute pits.
Until NNSA provides a public copy of report on plutonium and pit aging, the draft PEIS must be put on hold. Without such a report, which should have been prepared years ago, there is little evidence that NNSA can justify costly new pit production.
What new pits (of various designs) are for must be revealed in the draft PEIS. It appears that the first pits would be for the Sentinel ICBM and the next pits for the US-UK Submarine Launched Ballistic Missile (SLBM). And, more new weapons are already slated to be produced. All of these weapons would potentially fuel a new nuclear arms race with China and Russia. Additionally, it appears that NNSA’s goal is to replace all pits in all 3800 deployed and active nuclear weapons, which alone indicates non-compliance with the NPT. It appears that the U.S. intends to have these weapons ready for nuclear war and not just for “deterrence,” an ill-defined term used to justify all new nuclear weapons. Increased spending on those weapons and associated production facilities undermines national and global security.
As DOE’s Pantex site in Texas stores up to 20,000 pits removed from weapons, NNSA must show why reuse of these pits isn’t possible. It appears that old pits will be reused for the Sentinel missile, showing pit reuse is possible.
A new estimate of the costs of the proposed pit plant at the Savannah River Site must be presented. The Fiscal Year 2024 DOE budget included a cost estimate of $18 billion to $25 billion. But this estimate did not include the $5 billion already sunk into the building NNSA wants to use for pit production (when it was to be used for making plutonium fuel, MOX, before that troubled project was terminated in 2017). What is the overall cost of pit production at all involved DOE sites over the life of the program and when will an “Integrated Master Schedule” for pit production be provided, as requested by Congress?
Impacts to climate change must be discussed. Pit production will necessitate use of a large amount of electricity and fossil fuels for plutonium transportation, processing and production, with electricity in South Carolina likely coming from Dominion Energy, which is now pursuing a large new, gas-fired power-plant project.
Environmental justice must be fully reviewed, especially impacts to pueblos near Los Alamos and to African-American communities downwind and downriver of SRS, including impacts across the Savannah River in Burke County, Georgia.
The draft PEIS must discuss in detail the generation of low-level nuclear waste (LLW), including volumes generated and how it will be stored and disposed of, whether in private facilities, at SRS or Los Alamos or at DOE’s LLW facility in Nevada. At SRS, impacts of dumping of LLW into unlined, surface trenches above groundwater must be discussed.
Impacts to the environment and workers and public health of generation of plutonium waste (transuranic waste) must be discussed. Volumes of such waste generated and its disposal in the Waste Isolation Pilot Plant (WIPP) in New Mexico must be reviewed in detail, with annual production amounts revealed. Compliance with the New Mexico Environment Department’s license for WIPP, which prioritizes disposal of TRU waste from New Mexico, must be discussed. The impact on pit production of abrupt closure of WIPP due to an accident, as we saw in 2014, must be discussed.
The schedule and amounts of plutonium to be shipped into and out South Carolina and New Mexico or any other DOE site must be discussed. What would be the lifetime of new pit facilities? How would they be decommissioned, including if operation was abruptly stopped and not resumed?
Risks to the environment and workers and public health of plutonium purification and processing into pits must be reviewed, with close attention paid to the risks of plutonium leaks and inadvertent nuclear criticalities. Possible release of plutonium in various accident scenarios must be discussed.
Thank you for including an in-depth discussion about the above points in the draft PEIS.
Sincerely,
Name
Address (if you want to include it)
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email (include if you want to include it and get on the PEIS mailing list – they won’t send much)