SRS Plutonium pit production public comments due June 2, 2020

Email: NEPA-SRS@srs.gov (preferred)

Please use the subject line: Draft SRS Pit Production EIS Comment

Or send your hard copy comments via U.S. mail to: Ms. Jennifer Nelson, NEPA Document Manager, National Nuclear Security Administration, Savannah River Field Office, P.O. Box A, Aiken, SC 29802

Here below are sample comments you can use to write your own for submission to DOE/NNSA by the June 2, 2020 deadline.

On May 9, 2020 -- the eve of Mother's Day, as is mentioned below -- Beyond Nuclear submitted the following comments to DOE/NNSA on a closely related matter, the expansion of nuclear weapons plutonium pit production at Los Alamos National Lab in New Mexico. In fact, Beyond Nuclear's comments, below, to DOE/NNSA re: LANL, were taken and adopted from comments made verbally by Beyond Nuclear on April 30, 2020 during a DOE/NNSA webinar and call-in public comment meeting re: the commencement of plutonium pit production for nuclear weapons for the first time ever at SRS, SC. Feel free to copy Beyond Nuclear's comments below verbatim, or edit them as you see fit. Be sure to "translate" LANL-related comments over to SRS-related comments for this June 2nd SRS deadline.

Public comment on LANL SWEIS SA (DOE/EIS-0380-SA-06, March 2020), submitted by Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear

May 9, 2020

NNSA Los Alamos Field Office

Comments: LANL SWEIS SA

3747 West Jemez Road

Los Alamos, NM 87544

By email to: lanlsweissa@nnsa.doe.gov

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). These comments are submitted on behalf of our members and supporters in New Mexico, and beyond across the United States of America.

There is a need for a Programmatic Environmental Impact Statement (PEIS) to review all options across the U.S. Department of Energy complex, concerning plutonium pit production for nuclear weapons, including the option to not construct new facilities to produce pits at Savannah River Site (SRS) for the first time, and for expanded plutonium pit production at Los Alamos National Lab.

A bait and switch has been played on the American people. $7 billion in hard-earned U.S. taxpayer money was wasted on the now abandoned MOX FFF (Mixed plutonium-uranium Oxide Fuel Fabrication Facility) at SRS. DOE and NNSA said one thing, and are now doing the opposite. The irony and hypocrisy is extreme, first claiming to be turning "Swords into Plowshares," in converting weapons-grade plutonium excess to military needs, into "Atoms for Peace" nuclear fuel for commercial electricity reactors, as a supposed non-proliferation program. But from the very beginning, anti-nuclear power critics of the MOX FFF scheme called instead for immobilization -- mixing the weapons-grade plutonium back into the high-level radioactive waste (HLRW) from which it came in the first place, and then treating the forever deadly HLRW re-mixed with weapons-grade plutonium as just that, to be ultimately disposed of at a deep geologic repository found suitable for such after having passed a long list of stringent legal, technical, and social acceptance criteria. So what is this current nuclear weapons plutonium pit production plan? Plowshares into Swords? Swords into Swords? The icing on the cake of irony and hypocrisy is the use of the MOX FFF facility itself for nuclear weapons plutonium pit production, for the first time ever at SRS. Swords into Plowshares transformed into Swords into Swords. The mendacity is on full display for all the world to see.

The added environmental justice (EJ) burden of expanded plutonium pit production for nuclear weaponry at LANL is unacceptable. The map entitled "Water, Air, and Land: A Sacred Trust," by Deborah Reade, shows the very large number of nuclear, fossil fuel, and other hazardous industries and activities that have long harmed New Mexico (a state with a large percentage of Native American and Hispanic residents, and also a state that suffers near the very bottom of many socio-economic indicators regarding income, health care, education, etc.), and still do so. I have attached this map to this email as an addendum to our public comments. The safety, health, and environmental risks associated with expanded plutonium pit production for nuclear weapons at Los Alamos National Lab are an unacceptable EJ burden, especially for the Pueblo Indian nations whose land LANL occupies, but also for the rest of the state of New Mexico downwind, downstream, up the food chain, and down the generations, including its large Hispanic population.

Another aspect of this unacceptable scheme that must be addressed in a PEIS is its harm and risk to our national security. Beginning with a 2007 Wall Street Journal op-ed, the "Four Horsemen of the Nuclear Apocalypse" -- former Secretaries of State Henry Kissinger and George Schultz, former Defense Secretary William Perry, and former U.S. Senator Sam Nunn -- warned about the existential threat to the U.S. from nuclear weapons in the hands of enemies and even terrorist groups. They have since repeatedly called for abolition of nuclear weapons worldwide, as an essential safeguard of U.S. national security. If even "nuclear hawks" like Kissinger and Schultz fear the existential threat to the U.S. from the continued existence of nuclear weapons, DOE/NNSA and U.S. government policy makers at the highest levels should take heed, before it is too late. This plutonium pit production expansion plan at LANL, and the commencement of such at SRS, flies in the face of such dire warnings.

The example set and message sent by this plutonium pit production expansion scheme at LANL, and its commencement at SRS, increases the risk of nuclear weapons proliferation worldwide. This represents an increasing risk of actual nuclear warfare taking place, which could prove omnicidal.

There is increased environmental risk to LANL's environs out to a great distance, not just from routine operations, but also from the potential for a catastrophic release of ultra-hazardous plutonium onto the winds and waters.

As mentioned above, there is high risk -- actually a guarantee -- of violating EJ principles.

Under standard National Environmental Policy Act (NEPA) parlance, these are LARGE impacts. They should be treated as such in a comprehensive PEIS, not given short shrift by a slapdash, shallow, half-baked Supplemental Analysis.

And what about the Treaty on the Prohibition of Nuclear Weapons, also known as the Nuclear Weapon Ban Treaty? 36 state parties have already ratified it in less than three years. There are already a total of 81 state party signatories as well. If just 14 more state party signatories ratify this treaty, it will enter into the force of international law. The United States, and other countries possessing nuclear weapons, will be rogue nations, violating international law. This plutonium pit production program at LANL and SRS would be yet another violation of that impending treaty. In that sense, the plutonium pit production plan undermines our standing in the world.

And what about the 50-year old Nuclear Non-proliferation Treaty, the NPT. As posted online here <https://www.un.org/en/conf/npt/2005/npttreaty.html>, Article VI of the NPT states:

Article VI

Each of the Parties to the Treaty undertakes 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, and on a treaty on general and complete disarmament under strict and effective international control.

The LANL/SRS plutonium pit production expansion/commencement scheme flies in the face of the U.S.'s 50-year old NPT Article VI commitments. As a signatory of the NPT, the U.S. would again compound its violation of this treaty -- binding international law -- by pursuing this plutonium pit production expansion plan at LANL. And as the U.S. Constitution states, treaties are the highest law of the land, equal in stature to the U.S Constitution itself.

The Energy Secretary, and the NNSA Administrator, have sworn an Oath of Office that states:

I do solemnly swear (or affirm) that I will support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same; that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office on which I am about to enter: So help me God.

Since treaties are the highest law of the land, equal in stature to the U.S. Constitution itself, this means that the NPT commitments of the U.S. must be met. Plutonium pit production expansion at LANL, and its commencement at SRS, flies in the face of that.

And since plutonium pit production expansion at LANL, and its commencement at SRS, is connected to new weapons designs, this raises the specter of renewed nuclear weapons testing at the Nevada National Security Site (NNSS, formerly known as the NTS, Nevada Test Site). But the NTS's establishment in 1951, and nuclear weapons testing and other activities there ever since, is a flagrant violation of the Treaty of Ruby Valley of 1863, which the U.S. entered into with the Western Shoshone Indian Nation. Given the further violation of this highest law of the land, equal in stature to the U.S. Constitution itself, any planning regarding renewed nuclear weapons testing at the NNSS, located on Western Shoshone lands (Newe Sogobia in Shoshone language), must cease and desist immediately, before it starts.

The same logic applies to any notions of dumping any radioactive wastes from LANL or SRS at the NNSS. As NNSS is located on Western Shoshone land (the Western Shoshone land title affirmed by treaty right), DOE/NNSA have no right to dump radioactive waste there. This includes any wastes generated by expanded plutonium pit production at LANL, or its commencement at SRS. But it also applies to any dumping of irradiated nuclear fuel, or high-level radioactive waste, associated with the reactor-production and reprocessing of weapons-grade plutonium in the first place, as at Yucca Mountain, Nevada, located on the edge of the NNSS, also on Western Shoshone treaty lands.

The 75th annual commemorations of Trinity, Hiroshima, and Nagasaki will take place this July 16, August 6, and August 9, respectively. As shown by Deborah Reade's "Water, Air, and Land: A Sacred Trust" map, attached below and discussed above, Hispanic and Native American New Mexicans were disproportionately impacted as the very first Downwinders of the Atomic Age, at Trinity. Even the uranium mining in places like the Four Corners, that fed the nuclear arms race, has harmed Navajo/Diné and Pueblo Indian peoples disproportionately. But so has nuclear weapons activities at LANL (and Sandia) ever since. Such environmental injustice must end. That's one reason why expanded plutonium pit production at LANL must not go forward.

But as the Hibakusha, the survivors from the U.S. atomic bombings of Hiroshima and Nagasaki, Japan, have pleaded for 75 long years, what happened to them and their families can never be allowed to happen again. And yet expanded plutonium pit production at LANL, and its commencement at SRS, would increase the risk of nuclear war happening again.

The Kings Bay Plowshares Seven, scheduled to be sentenced for their non-violent civil disobedience action in Georgia dedicated to the memory of the Reverend Doctor Martin Luther King, Jr., invoked the prophecy of Isaiah:

And he shall judge among the nations, and shall rebuke many people: and they shall beat their swords into plowshares, and their spears into pruninghooks: nation shall not lift up sword against nation, neither shall they learn war any more. (Isaiah 2:4).

The Kings Bay Plowshares Seven are scheduled for sentencing at the end of this month. Their non-violent civil disobedience action took place on April 4, 2018 -- the 50th annual commemoration of the assassination of the Rev. Dr. MLK, Jr. The action was dedicated to addressing the "triple evils," as identified by MLK in 1967: "[T]he evil of racism, the evil of poverty, and the evil of war."

The EJ burdens mentioned above include the environmental injustice of radioactive racism, which would be exacerbated by expanded plutonium pit production at LANL, and its commencement at SRS.

The expenditure of billions of dollars of hard-earned U.S. taxpayer money for expanded plutonium pit production at LANL, and brand new pit production at SRS, would exacerbate the evil of poverty. As President Eisenhower put it, "Every gun that is made, every warship launched, every rocket fired signifies, in the final sense, a theft from those who hunger and are not fed, those who are cold and are not clothed." The Covid-19 pandemic is making the evil of poverty and disparity plain for all to see. Expanded plutonium pit production at LANL, and new plutonium pit production at SRS, does not address this current pandemic, nor the next pandemic, nor countless other health and wealth disparities in this country.

The following historic marker stands in St. Mary's Park, in downtown Monroe, Michigan, on the banks of the River Raisin. Monroe County "hosts" the dangerous and controversial Fermi nuclear power plant. The sign reads:

DR. MARTIN LUTHER KING, JR.

(1929-1968)

The words of Dr. Martin Luther King, Jr.

"If you are cut down in a movement that is designed to save the soul of a nation, then no other death could be more redemptive. We must somehow believe that unearned suffering is redemptive. We must work passionately and indefatigably to bridge the gulf between our scientific progress and our moral progress. One of the great problems of mankind is that we suffer from a poverty of the spirit which stands in glaring contrast to our scientific and technological  abundance. The richer we have become materially, the poorer we have become morally and spiritually."

The "host" communities of Los Alamos and New Mexico, as well as SRS and South Carolina, should not be blinded by radioactive dollar signs. The Faustian fission of deterrence is another false idol being worshipped, at all of our peril as inhabitants of planet Earth.

Lastly, on the eve of Mother's Day, it is good to remember the words of its feminist peace activist founder, Julia Ward Howe.

Here are the words of her original Mother's Day Proclamation:

Mother’s Day Proclamation, 1870

By Julia Ward Howe

Arise, then, women of this day!

Arise, all women who have hearts, Whether our baptism be of water or of tears!

Say firmly: “We will not have great questions decided by irrelevant agencies, Our husbands will not come to us, reeking with carnage, for caresses and applause. Our sons shall not be taken from us to unlearn All that we have been able to teach them of charity, mercy and patience. We, the women of one country, will be too tender of those of another country To allow our sons to be trained to injure theirs.”

From the bosom of the devastated Earth a voice goes up with our own. It says: “Disarm! Disarm! The sword of murder is not the balance of justice.” Blood does not wipe out dishonor, nor violence indicate possession. As men have often forsaken the plough and the anvil at the summons of war, Let women now leave all that may be left of home for a great and earnest day of counsel.

Let them meet first, as women, to bewail and commemorate the dead. Let them solemnly take counsel with each other as to the means Whereby the great human family can live in peace, Each bearing after his own time the sacred impress, not of Caesar, But of God.

In the name of womanhood and humanity, I earnestly ask That a general congress of women without limit of nationality May be appointed and held at someplace deemed most convenient And at the earliest period consistent with its objects, To promote the alliance of the different nationalities, The amicable settlement of international questions,

The great and general interests of peace.

 

Plutonium pit production expansion at LANL, and its commencement at SRS, violates Julia Ward Howe's peaceful vision for the establishment of Mother's Day.

Sincerely,

Kevin Kamps

Radioactive Waste Specialist, Beyond Nuclear

--
Kevin Kamps
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912

Cell: (240) 462-3216

kevin@beyondnuclear.org
www.beyondnuclear.org

Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic.