FORMAL COMMENTS ON PLUTONIUM PIT PRODUCTION AT SAVANNAH RIVER SITE

Comments on DOE’s National Nuclear Security Administration’s Draft Environmental Impact Statement on Plutonium Pit Production at Savannah River Site; Aiken, South Carolina

Re: Draft SRS Pit Production EIS – on Proposed SRS Plutonium Bomb Plant (PBP)

In Bizarre, Dangerous Twist, Facility at SRS Once Endlessly Touted as Pinnacle of Nuclear NonProliferation – MOX - Is Transformed into Factory for Proliferation & New Nuclear Arms Race
By Tom Clements, Director, Savannah River Site Watch, Columbia, SC, https://srswatch.org/
Draft EIS on Proposed SRS Plutonium Bomb Plant (SRS PBP) is posted here on NNSA’s website:
https://www.energy.gov/nepa/downloads/doeeis-0541-draft-environmental-impact-statement

Federal Register notice, April 3, 2020 Notice of Availability of Draft Environmental Impact Statement for Plutonium Pit Production at the Savannah River Site in South Carolina and Announcement of Public Hearing: https://www.govinfo.gov/content/pkg/FR-2020-04-03/pdf/2020-06557.pdf
DOE Ignores COVID-19 Threat, Diverts Resources to Planning for Nuclear War by Releasing Draft Environmental Study on SRS Plutonium Bomb Plant, April 3, 2020, news release by SRS Watch, Nuclear Watch New Mexico and Tri-Valley CARES, member groups of the Alliance for Nuclear Accountability: https://nukewatch.org/wp-content/uploads/2020/04/SRS-EIS-PR-4-3-20.pdf
These comments on the proposed SRS Plutonium Bomb Plant (PBP) and attachments are being submitted by Tom Clements, director of Savannah River Site Watch (SRS Watch), a non-profit, public-interest organization located in Columbia, South Carolina. I request that every comment and observation contained herein and information in the attachments be responded to in any final EIS, if such a document were to be issued. If any lawsuit under the National Environmental Policy Act (NEPA) were to develop on the pit issue, meticulous, detailed responses to these comments and attachments, especially regarding the legally required PEIS, are anticipated.

I formally repeat my request for this draft EIS record, as submitted in the Draft Supplement Analysis of the 2008 Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory for Plutonium Operations, DOE/EIS-0380-SA-06. A response is urgently needed:
NOTE: A FORMAL REQUEST is hereby being made for a supplement to the
Supplement Analysis or a revised draft SA to be prepared on the issues of 1) reuse
of plutonium pits in new and refurbished nuclear warheads and 2) production of
purified plutonium for production of new pits. Both issues can be discussed in a
single supplement document or a revised or edited supplement to the draft SA
released for public comment. These matters are too important and the discussion
about them is of such legal significance for them to simply be somehow included
in any final SA without opportunity for public comment. See details in comments
which follow. A discussion of these matters could also be contained in the
required Programmatic Environmental Impact Statement (PEIS). A formal
response from NNSA to this request is expected in the short term.

The above requested supplement must be prepared as the issues raised in my comments on the draft SA are inextricably intertwined with this draft EIS: plutonium pit “reuse” and
production of purified plutonium for pits, plutonium disposal and a new sodium-cooled nuclear reactor that DOE has proposed. Inexplicably, my request has so far been ignored. Please respond at [email protected].
SRS Watch notes that the highly complex and costly SRS pit project is being rushed, which raises red flags about its fate. The project currently is at the Critical Decsion-0 level and no massive financial resources have yet been prematurely committed. No Critical Decsion-1 has yet been made about going forward with the Plutonium Bomb Plant or not but the NNSA administrator said before the COVID-19 situation that the CD-1 decision could be coming in September 2020.

Read/Download full comments HERE 

NukeWatch NM: Scoping comments for the National Nuclear Security Administration’s (NNSA’s) draft environmental impact statement for plutonium pit production at the Savannah River Site

Dear SRS EIS NEPA Document Manager,
Nuclear Watch New Mexico is pleased to submit these scoping comments on the National
Nuclear Security Administration’s (NNSA’s) draft environmental impact statement for plutonium
pit production at the Savannah River Site.

The Need for a Programmatic Environmental Impact Statement

This is our first and primary concern, that NNSA must first complete a programmatic
environmental impact statement (PEIS) on its nation-wide plans for plutonium pit production, in
advance of the Savannah River Site-specific environmental impact statement. To get right to the
point, we argue that the SRS EIS process should go no further than this scoping period and
should resume only after a completed formal Record of Decision for a new or supplemental
PEIS

Read/Download the full document HERE