FORMAL COMMENTS ON PLUTONIUM PIT PRODUCTION AT LOS ALAMOS NATIONAL LABORATORY

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COLLECTIVE COMMENTS: on the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Dear LANL SWEIS SA Document Manager,

We respectfully submit these comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations (DOE/EIS-0380-SA-06, March 2020). That draft Supplement Analysis has “preliminarily” concluded that NNSA will NOT prepare a new LANL site-wide environmental impact statement, which is the wrong decision.

However, even before a new site-wide environmental impact statement (EIS) for Los Alamos Lab, we believe that NNSA is legally required to first complete a new programmatic environmental impact statement (PEIS) on its nation-wide plans for expanded plutonium pit production. This is necessary to 1) raise the production cap of 20 pits per year explicitly set by the 1997 Stockpile Stewardship and Management PEIS; and 2) because NNSA now proposes a second site, the Savannah River Site (SRS) in South Carolina, for redundant pit production, which is inherently a “programmatic” decision. NNSA argues that it can rely upon an outdated 2008 Complex Transformation PEIS which considered various levels of expanded plutonium pit production at five specific NNSA candidate sites. However, that outdated document did not consider simultaneous production at two sites. This changed circumstance is justifiable cause alone for a new programmatic environmental impact statement.

Read/Download full collective comments HERE 


NukeWatch NM: comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Dear LANL SWEIS SA Document Manager,

We respectfully submit these comments for the National Nuclear Security Administration’s (NNSA’s) Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory (LANL) for Plutonium Operations

Through comprehensive research, education, and effective citizen action, Nuclear Watch New Mexico seeks to promote safety and environmental protection at regional nuclear facilities; mission diversification away from nuclear weapons programs; greater accountability and cleanup in the nation-wide nuclear weapons complex; and consistent U.S. leadership toward a world free of nuclear weapons.

These comments also incorporate by reference the attached comments submitted by Nuclear Watch and others regarding both the Complex Transformation PEIS Supplement Analysis and the proposed environmental impact statement for the repurposing of the MOX Fuel Fabrication Facility at the Savannah River Site. We believe both are relevant and directly connected issues which NNSA seeks to segment contrary to statutory requirements under the National Environmental Policy Act.

Read/Download full comments HERE 


NukeWatch NM: Comments on NNSA’s Draft Supplement Analysis of the 2008 Complex Transformation PEIS that seeks to raise plutonium pit production from 20 pits per year to more than 80.

Dear NEPA Document Manager:

The stated purpose of the National Nuclear Security Administration’s (NNSA’s) Supplement Analysis of the 2008 Complex Transformation Programmatic Environmental Impact Statement is:

“… to allow NNSA to determine whether, prior to proceeding with the effort to produce plutonium pits at a rate of no fewer than 80 pits per year by 2030, the existing Complex Transformation SPEIS should be supplemented, a new environmental impact statement should be prepared, or no further National Environmental Policy Act (NEPA) analysis is required. The Draft SA [Supplement Analysis] preliminarily concludes that further NEPA documentation at a programmatic level is not required; however, NNSA will consider comments on this Draft SA and publish a Final SA.” 

In my view, to meet legal NEPA requirements NNSA must complete a new programmatic environmental impact statement (PEIS) on its nation-wide plans for expanded production of plutonium pits, the radioactive cores of nuclear weapons. Simply amending the Record of Decision for the 2008 Complex Transformation (CT) PEIS, as NNSA plans to do, will not be sufficient to formally raise the level of production from the level of 20 pits per year at the Los Alamos National Laboratory (LANL) sanctioned by the original1996 Stockpile Stewardship and Management PEIS.

Read/Download the full document HERE 


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Click the image to view and download this large printable map of DOE sites, commercial reactors, nuclear waste dumps, nuclear transportation routes, surface waters near sites and transport routes, and underlying aquifers. This map was prepared by Deborah Reade for the Alliance for Nuclear Accountability.

Nuclear Watch Interactive Map – U.S. Nuclear Weapons Complex

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