LANL Plans to Address Possibly Exploding Drums Shipped to Texas in 2014

Waste Control Specialists near Andrews TX
Aerial View of Waste Control Specialists (WCS) on the TX/NM state line

Los Alamos National Laboratory (LANL) has given itself a Categorical Exclusion (CX) under National Environmental Policy Act (NEPA) for the removal, relocation, and examination of transuranic (TRU) waste drums at Waste Control Specialists (WCS). These drums are similar to the ones that forced WIPP to close in 2014. LANL officials decided that formal environmental assessments, with public input, of the movement of the possibly exploding waste drums are not needed.

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Guest Blog: Associate Director of Physicians for Social Responsibility-Los Angeles, Denise Duffield, on the Fight to Clean up California’s Contaminated Santa Susana Field Laboratory (SSFL)

Dear Friends and Colleagues:

Tonight, MSNBC will air a powerful documentary called “In the Dark of the Valley” at 7 p.m. PST/ 10 p.m. EST. The film follows the story of Melissa Bumstead, a mother whose search for answers about her young daughter’s cancer leads her to the contaminated Santa Susana Field Laboratory (SSFL), a former nuclear and rocket engine testing site near Los Angeles. I have been involved in the fight to clean up SSFL for 15 years, and PSR-LA has been involved for over 30 years. PSR-LA Board President Dr. Bob Dodge and I are featured in the film, along with our longtime ally Dan Hirsch, President of Committee to Bridge the Gap; generations of SSFL cleanup activists, and many others.

I urge you to watch the documentary tonight or record it to watch later. Not only is the film masterfully done and visually stunning, it manages to capture the heart of one of the longest and most intensely fought battles to clean up a contaminated site in the US. That’s a big deal.

I’m writing to you all today because as I reflect on the fight to cleanup SSFL — the struggles, the hard work, the heartache, the setbacks, the frustration, the power of the forces we’re up against, the greenwashing, the gaslighting,the personal sacrifices made by so many, the folks we’ve lost along the way — the fact that this film was made so well and is going to be broadcast nationally is more than a big deal. It’s a victory. And victories, especially in these troubled times, should be shared and savored. Particularly for those of you who don’t know as much about SSFL, understanding just how brutal SSFL cleanup advocacy is, and how amazing the community and cleanup advocates are, makes this film — this victory — even sweeter.

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Current U.S. Nuclear Weapons Issues Updates — November 15, 2021

The current Continuing Resolution keeping the government running expires 12/3. Another Continuing Resolution is likely.

The Pentagon has released a major threat assessment of China at https://media.defense.gov/2021/Nov/03/2002885874/-1/-1/0/2021-CMPR-FINAL.PDF.

Under “Nuclear Capabilities” it concludes:

► Over the next decade, the PRC [People’s Republic of China] aims to modernize, diversify, and expand its nuclear forces.
► The PRC is investing in, and expanding, the number of its land-, sea-, and air-based nuclear delivery platforms and constructing the infrastructure necessary to support this major expansion of its nuclear forces.
► The PRC is also supporting this expansion by increasing its capacity to produce and separate plutonium by constructing fast breeder reactors and reprocessing facilities.
► The accelerating pace of the PRC’s nuclear expansion may enable the PRC to have up to 700 deliverable nuclear warheads by 2027. The PRC likely intends to have at least 1,000 warheads by 2030, exceeding the pace and size the DoD projected in 2020.
► The PRC has possibly already established a nascent “nuclear triad” with the development of a nuclear capable air-launched ballistic missile (ALBM) and improvement of its ground and sea-based nuclear capabilities.
► New developments in 2020 further suggest that the PRC intends to increase the peacetime readiness of its nuclear forces by moving to a launch-on-warning (LOW) posture with an expanded silo-based force.

This is bound to have a major influence on Biden’s Nuclear Posture Review, to be released in early 2022. China’s expansion of its nuclear weapons capabilities, along with U.S. and Russian “modernization” programs, may also be big issues at the January 2022 NonProliferation Treaty Review Conference.

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An Environmental & Nuclear Disaster in LA’s Backyard: How Much Contamination Really Fell on Top of Communities from Thousand Oaks to Simi Valley from the Woolsey Fire?

The Santa Susana Field Laboratory (SSFL) is a 3,000 acre site sitting on top of the San Fernando and Simi Valleys in California, located less than 30 miles from Malibu. In 1947 the site was developed as a central location for U.S. rocket engine testing and space exploration, and in the 1950’s SSFL began experimenting with constructing nuclear reactors.

Ten nuclear reactors were built in total, and tens of thousands of rocket, energy, and weapons tests took place there from when the laboratory went into operation in 1947 until it’s closure in 2006. The rocket engine tests specifically produced numerous toxic spills and releases. The nuclear reactors built include a “Hot Lab” to “cut up irradiated reactor fuel from around the country,” “plutonium and uranium-carbide fuel fabrication facilities,” and a “sodium burn pit in which open-air burning of contaminated reactor components took place.” One of the reactors, the Sodium Reactor Experiment, experienced a partial nuclear meltdown in 1959, and two other reactors experienced accidents with fuel damage as well.

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Current U.S. Nuclear Weapons Issues Updates — October 15, 2021

Congress passed a continuing resolution that keeps the government running until December 3. It freezes funding at 2021 levels which at least prevents short-term budget increases for nuclear weapons modernization programs and has no “anomalies” (i.e. exceptions) for these programs. That said, Biden passed on most of Trump’s nuclear weapons excesses forward in his FY 2022 budget, so it’s not like it makes a whole lot of difference.

Mitch McConnell agreed to let the Democrats raise the national debt ceiling, thereby averting national and international economic disaster. How gracious of him.

Democrats and Republicans joined together to roll Biden on the money in the FY 2023 Defense Authorization Act for the entire military (including the National Nuclear Security Administration (NNSA). These bipartisan porkmeisters added $23.9 billion for $768 billion in total defense spending. The new bogeyman China was repeatedly invoked as the rationale (in comparison China now spends around $250 billion annually on its military).
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International Day for the Total Elimination of Nuclear Weapons 2021

International Day for the Total Elimination of Nuclear Weapons 2021

Today, Sunday, September 26, 2021, marks the United Nations International Day for the Total Elimination of Nuclear Weapons. The United Nations has been working toward achieving global nuclear disarmament since the organization’s inception; it was the subject of the General Assembly’s first resolution in 1946, with a mandate to make specific proposals for the elimination of atomic weapons and all other major weapons adaptable to mass destruction. The International Day for the Total Elimination of Nuclear Weapons has been observed annually since 2014, serving as a tool to enhance public awareness and education about the threat posed to humanity by nuclear weapons and the necessity for their total elimination. In 2013, the year the International Day for the Total Elimination of Nuclear Weapons was introduced, the President of the General Assembly noted that a “renewed international focus on the catastrophic consequences of nuclear weapons has led to a reinvigoration of international nuclear disarmament efforts.”

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This is OUR Neighborhood: Expanding the Capacity of New Mexico’s Nuclear Waste Repository Affects Communities across the Country.

This is OUR Neighborhood: Expanding the Capacity of New Mexico’s Nuclear Waste Repository Affects Communities across the Country.

The original mission of the Waste Isolation Pilot Plant (WIPP) in southeastern New Mexico had two specific stipulations: it was to be the FIRST and only operating underground nuclear waste repository in U.S; and it is ONLY authorized to take a certain kind of nuclear weapons waste – legacy transuranic (TRU) waste. In December of last year, the U.S. Department of Energy published a notice of intent to expand WIPP. The notice details expansion of the plant in two ways: capacities and types of waste permissible, as well as extended storage/operation timelines. The federal government’s plans would expand the size of the nuclear weapons dump to more than twice its current size and more than is allowed: Federal law and legal agreements with New Mexico clearly limit the amount of waste at WIPP, but the expansion would allow more than that capacity (as described in the April 2020 National Academy of Sciences Report “Review of the Department of Energy’s Plans for Disposal of Surplus Plutonium in the Waste Isolation Pilot Plant.”) This means an increased volume of waste, as well as an increased number of shipments travelling to WIPP over the entire rest of the century.

The original complete set of legal permits, contracts and laws governing WIPP includes the Federal Resource Conservation and Recovery Act (RCRA), which 1) gives the New Mexico Environment Department regulation over the permit for DOE operation of WIPP and 2) limits amount of waste and how long WIPP operates (2024);

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76 Years After the First Nuclear Bomb Test, the U.S. is Still Dead Set on Building Weapons of Mass Destruction

76 Years After the First Nuclear Bomb Test, the U.S. is Still Dead Set on Building New Weapons of Mass Destruction

Last week, July 16 2021, marked the 76th anniversary of the world’s first nuclear bomb explosion. Within another month, memorials and commemorations will be held for the Japanese cities of Hiroshima and Nagasaki, which the U.S. bombed on 6 and 9 August 1945, respectively. Although it was unknown to most residents of New Mexico until after the United States’ atomic bombing of Japan, the citizens and communities in the southern region of the state were in fact the first nuclear victims.

When the U.S. Army detonated an atomic bomb on July 16, 1945 at 5:29 a.m., “its thunderous roar during the rainy season knocked people from breakfast tables in Tularosa and sent others on the Mescalero Apache reservation into hiding.” (axios.com) Hispanics and Mescalero Apache tribal members in New Mexico are working to pressure lawmakers to compensate those who have suffered extremely because of the experiment. Rare forms of cancer and other health problems have been discovered in those living near the site of the Trinity Test, and the vast, noxious consequences of this experiment have had lasting impact on now multiple, entire generations.

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South Carolina Environmental Law Project and Nuclear Watchdogs Virtual Press Conference

Nuclear Watch New Mexico, along with other watchdog groups, has announced a lawsuit against the Biden administration over its expanded production of plutonium cores for the U.S. nuclear weapons “modernization” plans. There has been inadequate environmental review by federal agencies, who have failed to detail potential impacts of the projects around communities in New Mexico and South Carolina.

The lawsuit was filed against the Energy Department and the National Nuclear Security Administration demanding the federal agency that oversees U.S. nuclear research and bombmaking must “take a legally required ‘hard look’ at impacts on local communities and possible alternatives before expanding manufacturing of the plutonium cores used to trigger nuclear weapons.”

The push from U.S. officials to “modernize” the country’s nuclear arsenal cites only general global security concerns that do not justify the science and brand new, untested technology that will be necessary to the task. citing global security concerns. Although “most of the plutonium cores currently in the stockpile date back to the 1970s and 1980s,” scientific experts estimate that plutonium pits will last 100 years or more., and on warhead type, the best estimate of minimum pit life is 85–100 years.minimum.

Los Alamos National Laboratory in northern New Mexico and the Savannah River Site near Aiken, South Carolina face enormous (and, frankly, unrealistic) deadlines to produce a massive number of plutonium cores in coming years – 50 or more cores at South Carolina and 30 or more at Los Alamos National Lab. The Savannah River Site location now has estimated costs up to $11.1 billion, with a completion date ranging from 2032 to 2035. The U.S. doesn’t need the new plutonium cores with the taxpayer bearing the burden for the expense of lagging deadlines and bloated budgets.

“The watchdog groups said Tuesday that the agency took a piecemeal approach to decide on locating the production at Los Alamos and the Savannah River Site, where nearby communities are already underrepresented and underserved.”

Tom Clements of Savannah River Site Watch said the South Carolina location was picked for political reasons following the failure of a facility designed to convert weapons-grade plutonium into commercial nuclear fuel. As the Savannah River Site has never served as a storage or production site for the pits in its history, establishing pit construction there would be “a daunting technical challenge that has not been properly reviewed,” Clements said.

With very real, current threats the U.S. is facing right now, we don’t need another Rocky Flats situation in New Mexico or South Carolina where a $7 billion, yearslong cleanup is required after the facilities fail due to leaks, fires and environmental violations, doing irreparable damage to the earth and placing communities there in unequivocal peril.

Cleanup Funding Request at Los Alamos Would Be Needed Increase

DOE Environmental Management released the Fiscal Year 2022 (FY22) Congressional Budget Request and asked for a $107.5 million increase over last year for legacy cleanup at Los Alamos National Laboratory (LANL). The FY22 EM funding request for cleanup at LANL totaled $333.5 million, which was a record request for cleanup at the Lab.

The Budget Request gives lifecycle costs. LANL has spent $3.8 billion on cleanup from 1997 to 2020. The high estimate is $4.6 billion for FY21 to FY90. This gives a total lifecycle cost of $8.4 billion from 1997 through 2090. The assumption included with these estimates is that most of the waste will remain buried at LANL. This is the first time DOE has mentioned legacy cleanup lasting until 2090. Last year the completion date was given as 2036.

Is legacy cleanup completion being pushed back to prioritize pit production? If DOE starts spending more on cleanup like this year in the future, shouldn’t cleanup take less time? The numbers work out to DOE only spending an average of $50 million between now and 2090, so DOE must not have plans to spend $330 million annually through 2090.

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Modernization: The Mainspring of NNSA FY 2022 Budget Request in the Form of Ballooning SRS Pit Costs

The National Nuclear Security Administration’s detailed fiscal year 2022 budget request was (partially) unveiled last week on Friday, May 28, in the evening before a long holiday weekend. The Biden Administration’s total NNSA FY22 budget request is just under $20 billion, requesting of $15.48 billion for NNSA “Total Weapons Activities” and following suit with Trump’s excessive nuclear weapons budget of $15.35 billion that Congress appropriated for FY 2021.

Of particular note in the budget request is that it will cost more than double what the National Nuclear Security Administration had previously estimated for the total of DOE’s Plutonium Bomb Plant construction at Savannah River Site in South Carolina. The facility would be a converted production plant for the fabrication of plutonium “pits,” the triggers for nuclear warheads. The cost for the plant has ballooned from the previous estimate of $4.6 billion to a now staggering $11.1 billion. What’s more, the schedule for the facility’s initial operation has slipped up to five years. The plans for the SRS Plutonium Bomb Plant have already run far over budget and fallen behind schedule, and “these troubling and potentially debilitating developments foreshadow problems to come to the challenging pit-production project,” according to the public interest group Savannah River Site Watch.

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MEDIA ADVISORY: WHAT TO LOOK FOR IN THE U.S. DEPARTMENT OF ENERGY’S FY 2022  NUCLEAR WEAPONS AND CLEANUP BUDGET REQUEST

For use with DOE’s scheduled budget release on Friday May 28, 2021
For more information, key contacts are listed below.

The White House is releasing its detailed Fiscal Year 2022 budget on Friday, May 28. A so-called “skinny budget” was released on April 9 that increased Department of Energy (DOE) funding to $46.1 billion, which reportedly includes major new investments in clean energy and climate change abatement. That said, historically roughly 60% of DOE’s funding has been earmarked for nuclear weapons production and cleanup of Cold War wastes and contamination. The pending budget release will finally provide details on those programs.

Because the budget release is so late Congress has already announced that it can’t consider the annual Defense Authorization Act until September. Related appropriations bills will no doubt be delayed too. This means that the government will probably have to run on a Continuing Resolution(s) for much of FY 2022 (which begins October 1, 2021).

The Alliance for Nuclear Accountability strongly opposed the massive 25% FY 2021 increase that the Trump Administration gave to the National Nuclear Security Administration’s (NNSA’s) nuclear weapons programs and proposed cuts to Department of Energy cleanup. In addition, DOE’s nuclear weapons and environmental management programs have been on the Government Accountability Office’s “High Risk List” for project mismanagement and waste of taxpayers’ dollars for 28 consecutive years. Related, the Congressional Budget Office (CBO) has just released a report that projects a 28% increase in costs for so-called “modernization” of U.S. nuclear forces that between the Defense Department and DOE is expected to cost around $1.7 trillion over 30 years.

The Alliance for Nuclear Accountability, a 34-year-old network of groups from communities downwind and downstream of U.S. nuclear weapons sites, will be analyzing the following critical issues. For details, contact the ANA leaders listed at the end of this Advisory.

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Virtual Advocacy for “Safety, Security, and Savings” at ANA DC Days:

May 26, 2021

Nuclear Watch New Mexico virtually visited Washington, DC this month to participate in the Alliance for Nuclear Accountability’s “DC Days,” an annual event where organizations from across the nation, whose members are directly affected by nuclear weapons production and the incidental health and environmental consequences, make their voice heard to federal policy makers.

Nuclear Watch NM was focused on opposing new plutonium pit production at Savannah River Site and Los Alamos, pushing for safe and secure toxic cleanup and prioritizing public health while saving billions by terminating ill-conceived new nuclear weapons programs. View more information on these issues in the Alliance for Nuclear Accountability’s new report, “Safety, Security, and Savings,” which describes in detail the foundation of our 2021 advocacy. The report includes a series of fact sheets and recommendations covering new warheads, bomb plants, nuclear waste, cleanup, and more.

Notice of Impending Lawsuit to DOE & NNSA Over Nuclear Bomb Core Plans from Environmental Groups

Nuclear Watch New Mexico, as part of a larger coalition of environmental groups, has threatened the federal government with a lawsuit over cross-country plans to produce plutonium pits, the cores at the heart of modern nuclear weapons.

A more comprehensive review should have been done on the plans to produce plutonium cores at Los Alamos and at the Savannah River Site in South Carolina. This lack of review violates the National Environmental Policy Act (NEPA) and would saddle already-burdened communities nearby the two DOE sites with significant quantities of toxic and radioactive waste, contravening President Biden’s executive order of making environmental justice a part of the mission of every agency. Here in New Mexico, we are well aware of how much our local community has already have been burdened with legacy contamination from previous defense work. While the budget continues to be cut and slashed for cleanup funding, the astronomical cost of modernizing the U.S. nuclear weapons arsenal continues to balloon out of proportion without NNSA or DOE batting an eyelash. The federal government’s plans are unnecessary and provocative – more plutonium pit production will result in more waste and help to fuel a new arms race.

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10 Years Since Fukushima Nuclear Disaster

10 Years Since Fukushima Nuclear Disaster

11 March 2021 marks the 10th anniversary of the triple catastrophe which marked the life of many residents of Eastern Japan: a powerful earthquake, deadly tsunami and nuclear meltdown that left almost 18,500 people killed or missing. Much has been achieved in disaster-hit areas but they are still seriously recovering, and the staggering loss of life and community is still being felt by the nation today. The impacts on communities from the ongoing dispersal of radioactive contamination released from the explosions at the Daiichi nuclear power plant in Fukushima have been disastrous. Tokyo will probably face a massive earthquake in the next 30 years, and Japan must prepare for this next big quake while the Fukushima nuclear meltdown on Japan’s north-eastern coast remains firmly in the minds of everyone there.

Since the disaster, tens of thousands of people have been displaced from their ancestral lands. The harm extends far beyond the immediate threat to health – as well as destroying livelihoods, it has destroyed an entire way of life.

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Wildland Fire Prevention Still Lagging at LANL

Los Alamos National Laboratory (LANL) has had two major wildland fires — the Cerro Grande Fire in 2000 and the Las Conchas Fire in 2011. Each fire burned partially on Lab property within miles of several nuclear facilities. LANL’s wildfire prevention should be 100% in place and constantly updated. But a February 1, 2021, report by the DOE Inspector General found that activities designed to reduce the impact from wildland fire had not been fully implemented at LANL. The DOE-IG found that while the contractor, Triad, had identified fire risks, it had not completely implemented all measures to prevent serious fires.

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Leave Nuclear to the Sun: Solar Energy & Renewables are the Source of the Future

The nuclear energy industry has had a fraught year. Well…I mean, haven’t we all…But still, it’s pleasantly surprising to see such a looming giant begin to wither and fall. The nuclear power industry is failing, as evidenced not only by the alarming reports of fraud, corruption, and other fiascos that occurred at multiple nuclear facilities over the course of 2020, but also by the numbers that prove renewables are simply better for ALL of our futures – not just the nuclear business moguls our taxpayer dollars so generously continue to bail out.

Solar to be No. 1 in US for new 2021 electricity generating capacity

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Nuclear Weapons Have Always Been Immoral. Now They’re Illegal.

On 7 July 2017, the Treaty on the Prohibition of Nuclear Weapons (TPNW) was adopted by the UN General Assembly. Just over three years later, the TPNW reached the 50 national ratifications needed to become international law. The treaty will enter into force on January 22, 2012, and nuclear weapons will become officially illegal under international law. This day will represent a culmination of years of campaigning for nuclear weapons to be reframed as a collective humanitarian problem, one which requires prohibition and elimination, rather than a national military defense asset that needs to be managed and even upgraded.

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Second Public Meeting for Controversial Tritium Releases at the Los Alamos Lab

Because of overwhelming public demand and technical problems with the first virtual public meeting, the National Nuclear Security Administration is holding a second meeting on the Los Alamos National Laboratory’s (LANL’s) controversial plan to vent up to 100,000 curies of tritium gas. Tritium is a radioactive isotope of hydrogen, used to boost the explosive power of nuclear weapons. Most vented tritium will condense into water vapor which can then be readily ingested by living organisms, including humans. Fetuses are particularly at risk.

LANL’s nuclear weapons budget has doubled over the last decade to $2.9 billion in fiscal year 2021. But funding for so-called cleanup has remained flat at around $220 million, or 8% that of nuclear weapons. In fact, LANL plans to “cap and cover” some 200,000 cubic yards of radioactive and toxic wastes, leaving them permanently buried in unlined pits above our groundwater, some three miles uphill from the Rio Grande, and call it cleaned up. To add to this, the Lab now plans to dose the public by venting excess tritium.

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NNSA Head Props Up Nuclear Weapons Modernization…Again

In her September 17, 2020 testimony before before the Senate Armed Services Committee, Lisa E. Gordon-Hagerty, Administrator of the National Nuclear Security Administration, restated the ongoing company line that more money must be spent on the US nuclear weapons stockpile, or the whole enterprise might fall over.

She stated, “The need to now modernize our nuclear weapons stockpile and recapitalize the supporting infrastructure needed to produce and maintain that stockpile has reached a tipping point.”

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DOE Repeatedly Asks Safety Board for Time Extensions, Los Alamos Lab Asked for >150 Cleanup Milestone Extensions, But During Pandemic NNSA Rejects NM Senators’ Request for Extension of Public Comment on Plutonium Bomb Core Production

DOE Repeatedly Asks Safety Board for Time Extensions
Los Alamos National Laboratory’s Radiological Laboratory Utility Office Building (Source: Los Alamos National Laboratory)

Lisa Gordon-Hagerty, head of the National Nuclear Security Administration (NNSA), has rejected a request by New Mexico Senators Tom Udall and Martin Heinrich to extend the public comment period on expanded plutonium “pit” bomb core production because of the COVID-19 pandemic. In contrast, even in normal times NNSA and its parent Department of Energy routinely ask other government agencies for major time extensions when it comes to cleanup and independent oversight.

The two Senators requested a 45 day comment period extension on behalf of more than 120 organizations and individuals. Before that, Tom Udall and Martin Heinrich were among 24 Senators who asked the Office of Management and Budget to extend all federal public comment periods during the coronavirus national emergency.

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Letter With >120 Group & Individual Sign-Ons Asks Udall and Heinrich to Extend Public Comment Period on Los Alamos Lab Plutonium Bomb Core Production

Letter With >120 Group & Individual Sign-Ons Asks Udall and Heinrich to Extend Public Comment Period on Los Alamos Lab Plutonium Bomb Core Production

Today, on behalf of more than 120 groups and individuals, Nuclear Watch New Mexico sent a letter to New Mexico Senators Tom Udall and Martin Heinrich. It asks them to act upon their own words and demand that the public comment period be extended for plutonium “pit” bomb core production that the National Nuclear Security Administration (NNSA) is fast tracking during the coronavirus epidemic. As sitting members of the Senate Appropriations and Armed Services Committees, Udall and Heinrich are in strong positions to make that demand of NNSA.

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DOE Ignores COVID-19 Threat, Diverts Resources to Planning for Nuclear War by Releasing Draft Environmental Study on SRS Plutonium Bomb Plant

Today, in the middle of the growing coronavirus pandemic, the U.S. Department of Energy ignored the real national crisis and irresponsibly shifted its focus to planning for nuclear war, revealing plans to construct a Plutonium Bomb Plant (PBP) at the Savannah River Site (SRS) in South Carolina.

DOE’s semi-autonomous National Nuclear Security Administration (NNSA) today formally released the Draft Environmental Impact Statement for Plutonium Pit Production at the Savannah River Site in South Carolina, whose proposed action is to establish the production of plutonium “pits” (nuclear warhead cores) at SRS at a rate of up to 125 pits per year, with at least 50 pits per year by 2030 as the stated objective for now.

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LANL Plans to Release Up To ~100,000 Curies of Radioactive Gas

Santa Fe, NM – On March 11, the Los Alamos National Laboratory (LANL) sent the federal Environmental Protection Agency a formal notice that the Lab will intentionally release up to some 100,000 curies of tritium, a radioactive isotope of hydrogen gas, beginning April 17, 2020. 

An internal Lab document states that actual “anticipated emissions” could be half that because of tritium remaining behind in equipment but offers no documentation to substantiate it. During the 1980’s LANL arbitrarily used a self-declared “building shielding factor” not approved by the EPA that reduced its legally required annual calculated radioactive air dose to the public by a third. When that reduction was disallowed LANL was in fact in legal violation of the Clean Air Act. With that as an example, undocumented reductions in radioactive doses claimed by LANL should be viewed with suspicion.

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