Beyond Nuclear's Public Comment on the Draft Environmental Impact Statement (DEIS) for a New Plutonium Bomb Production Facility at the Savannah River Site in South Carolina

Ms. Jennifer Nelson
NEPA Compliance Officer, National Nuclear Security Administration
Savannah River Field Office, P.O. Box A, Aiken, South Carolina 29802
By email to NEPA-SRS@srs.gov

Re: Public Comment on the Draft Environmental Impact Statement (DEIS) for a New Plutonium Bomb Production Facility at the Savannah River Site in South Carolina

Dear Ms. Nelson and NNSA:

We are submitting the following comments on the proposed Savannah River Site Plutonium Processing Facility intended for the production of plutonium bomb cores, or “pits.” I ask that my comments be made part of the record.

1. A Programmatic Review of the Full Hazards of Pit Production is Necessary

The National Nuclear Security Administration’s (NNSA) plan to expand U.S. plutonium pit production to 80 or more new bomb cores per year relies on two production facilities, the Savannah River Site in SC and the Los Alamos Lab in NM.

Further, NNSA has listed seven more sites that are integral to its plan to expand pit production. They are: the Waste Isolation Pilot Plant in NM, the Lawrence Livermore National Lab in CA, the Nevada Nuclear Security Site, the Kansas City Plant, the Y-12 Complex in TN, the Pantex Plant in TX, and the Sandia National Lab in NM and CA. This totals nine facilities scattered across the map.

Instead of looking at the full picture, the NNSA has inappropriately fragmented its environmental review. This DEIS, which focuses solely on the Savannah River Site, is the only Environmental Impact Statement process that NNSA is presently undertaking on this project.

This situation must be remedied. Prior to issuing a final DEIS on the Savannah River Site, a comprehensive nationwide review of all of the interlocking risks, including transportation, should be prepared.

Therefore, I add my voice to that of Tri-Valley CAREs and other public interest groups to support preparation of an overarching Programmatic Environmental Impact Statement (PEIS) that would examine the “purpose and need” for expanded pit production as well as its potential impacts on communities all across the country.

2. A “Hard Look” at Alternatives is Required

NNSA’s plan to expand pit production is being driven by a new warhead under development at the Lawrence Livermore National Lab, the W87-1.

According to public documents from NNSA, the Government Accountability Office and other agencies, this fully new weapon design will involve a novel plutonium pit, unlike anything in the stockpile or in storage. This is a choice. The final EIS must analyze an alternative scenario in which the agency foregoes new-design pits. How many newly produced pits would be needed in 2030 (the due date for both the new bomb plant and the W87-1 warhead) if not for new design pits? Unfortunately, the DEIS dodges this issue.

Similarly, the DEIS is flawed because it does not adequately analyze a reasonable alternative involving the “reuse” of existing pits. There are some 15,000 to 20,000 plutonium pits in storage at the Pantex Plant, with lesser quantities stored elsewhere. Pit reuse is a proven technology. The final PEIS must fully consider the role pit reuse could play before rushing full speed ahead with a new bomb plant at the Savannah River Site as well as plans to expand pit production at Los Alamos.

Moreover, the DEIS does not address the role of novel warhead design in stimulating a dangerous, costly new global arms race. The agency cannot ignore the directly related cause and effect of developing new weapons and producing new pits for them. The potential impacts of spurring nuclear proliferation must be seriously considered.

3. Health Hazards to Workers and the Public Must Be More Fully Considered

Industrial scale plutonium pit production last took place at the Rocky Flats Plant in CO. It was shut down in 1989 following a raid by the FBI environmental crimes unit and the EPA. A full analysis of the Rocky Flats experience is lacking in the DEIS and must be included in the final EIS.

Plutonium fires at Rocky Flats created airborne pollution for miles around the site, reaching nearby towns and even the City of Denver. The full impacts of a plutonium fire at the Savannah River Site must be included in the final EIS.

The analysis must include site workers, first responders, and communities near the Savannah River Site, including Barnwell, SC and Shell Bluff, GA. The residents of these communities are primarily low-income and historically disadvantaged people of color. What is the plan to safeguard them? What about workers?

The DEIS also lacks other information needed to appropriately assess risks. The process for producing pits at the Savannah River Pits must be better defined in the final EIS. Similarly, a thorough discussion of the specific technology to be used to purify plutonium for new pit production must be included in the final EIS, with a full accounting of its potential health impacts.

4. Environmental Hazards Must be More Fully Considered

Pit production at the Savannah River Site would produce a host of chemical and nuclear waste streams. The DEIS shortchanges the analysis of their risks. Is dumping of low-level nuclear waste in unlined trenches being considered? Waste containment and management at the Savannah River Site have been problematic; the site was placed on the EPA “Superfund” list in 1989. The final EIS must comprehensively analyze the impacts of new production alongside the leaking wastes already in the environment.

Shouldn’t past pollution be remedied before new wastes are heaped on top of the old? This fundamental question is not fully answered in the DEIS. Indeed, pit production could distract from the main mission of the Savannah River Site (and its largest source of federal funding); namely, cleaning up tens of millions of gallons of waste products left over from past production of plutonium and nuclear weapons materials at the site.

5. The SRS Plutonium Bait and Switch

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.

(Beyond Nuclear, on behalf of its members and supporters near SRS, and across the country, also wants to state clearly that we are adamantly opposed to plutonium pit production for nuclear weapons anywhere, anytime. This includes at Los Alamos National Lab -- not "just" the proposed expansion of plutonium pit production at LANL, but also current plans for plutonium pit production at Los Alamos.)

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 Americans and all the world to see.

6. Environmental Justice

The added environmental justice (EJ) burden of plutonium pit production for nuclear weaponry at SRS is unacceptable. The SRS region already hosts way too many radioactive risks. SRS itself is a very badly radioactively contaminated vast area.

But very nearby there is also a former national dump for so-called "low" level radioactive waste at Barnwell, SC. For decades, up until about a decade ago, Barnwell served as the dump-site for 39 states' "low" level radioactive wastes (LLRW). Since, three states still dump LLRWs there. The dump has long suffered leaks into the surrounding community. A neighboring church yard had to be exhumed, to a deep depth, as LLRW, because the LLRW from Barnwell had reached and contaminated it via groundwater flow.

Also nearby are nuclear power plants, including Summer in South Carolina, and Vogtle in Georgia. Vogtle could become the largest single nuclear power plant in the country. It already has two large reactors. But two more reactors are under construction. "Just" the routine releases from Summer and Vogtle are bad enough (see: <http://static1.1.sqspcdn.com/static/f/356082/26605366/1444852853757/BN_RoutineRadioactiveReleases_Oct2015.pdf?token=zwsUExAyfOttAa88dOgh7qJ3NkE%3D>), and could get worse with age-related degradation. Vogtle will also represent both extremes of the reactor risk spectrum -- have breakdown phase increased risks at the Vogtle Units 1 and 2 reactors, combined with the break-in phase increased risks at the Vogtle 3 and 4 reactors, if they ever become operational (they are currently many billions of dollars over budget, and many years behind schedule, with challenges brought by Nuclear Watch South re: safety-significant ITAAC violations, and by Blue Ridge Environmental Defense League re: the nuclear island at Vogtle 3 dangerously sinking into the red Georgia clay. As BREDL's expert witness, nuclear engineer Arnie Gundersen of Fairewinds Energy Education, put it, "Islands are not supposed to sink." Such sinkage at the Midland nuclear power plant in Michigan led to the construction project's cancellation, even though one reactor was 90% complete, and the other was 50% complete. Billions of dollars were wasted on the cancelled Midland reactors, just as $9 billion of ratepayer money was wasted on Vogtle's twin new build at Summer, Units 2 and 3, cancelled some years ago.)

Underscoring the EJ violations that plutonium pit production at SRS would represent, is the fact that communities like Shell Bluff, Georgia, and Burke County, GA, are majority people of color. Burke County, according to the 2010 U.S. Census, is 49.5% Black or African American, 0.3% Asian, 0.2% Native American, 0.1% Pacific Islander, 1.1% from some other race and 1.3% from two or more races; 2.6% are Hispanic or Latino (of any race). Thus, the majority of the population of Burke County are people of color.

There is also a significant poverty problem in Burke County, despite (because of?!) the presence of so many nuclear power and nuclear weapons facilities in the immediate area. About 20.0% of families, and 25.7% of the population, were below the poverty line, including 38.0% of those under age 18, and 16.2% of those age 65 or over. (Citation: "DP03 SELECTED ECONOMIC CHARACTERISTICS – 2006-2010 American Community Survey 5-Year Estimates". United States Census Bureau. Archived from the original on February 13, 2020. Retrieved December 27, 2015.)

7. Unprecedented Plutonium Pit Production at SRS Would Harm Our National Security and Put It at Risk

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 state 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 unprecedented plutonium pit production plan at SRS, and its expansion at Los Alamos (as well as current plutonium pit production plans at LANL), flies in the face of such dire warnings as that repeated since 2007 by the "Four Horsemen of the Nuclear Apocalypse."

The example set and message sent by this plutonium pit production commencement at SRS, and its expansion at LANL (as well as current plutonium pit production plans at LANL), 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 SRS's and 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 this slapdash, shallow, half-baked Draft EIS.

And what about the Treaty on the Prohibition of Nuclear Weapons, also known as the Nuclear Weapon Ban Treaty? 37 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 13 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 programs at LANL (now proposed for expansion) and SRS (now proposed for the first time ever) would be yet another violation of that impending treaty. In that sense, the plutonium pit production plans, current and potential/proposed, undermine 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 schemes (as well as current plans for plutonium pit production at LANL) fly 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, as well as current such plans at LANL, and also unprecedented SRS plutonium pit production plans for nuclear weaponry. 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 (as well as current plutonium pit production plans 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 Trump administration's recent threat to restart full-scale nuclear weapons testing at the NNSS/NTS, for the first time since September 1992, as reported by the Washington Post on May 22, 2020, raises profound, dire alarm bells.

The same logic applies to any notion 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 (as well as currently planned 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. Such environmental injustice, and genocidal nuclear weapons use, must never happen again. That's one reason why expanded plutonium pit production at LANL (as well as current plans for plutonium pit production at LANL), and its commencement at SRS, must not go forward.

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 (as well as current such plans there), and its commencement at SRS, would increase the risk of nuclear war happening again.

The Hibakusha, in the person of Setsuko Thurlow, a survivor of the Hiroshima atomic bombing, who was 13 years old when it happened, shared the 2017 Nobel Peace Prize with the International Campaign to Abolish Nuclear Weapons, for their advocacy for the Treaty on the Prohibition of Nuclear Weapons, mentioned above.

The Kings Bay Plowshares Seven, scheduled to be sentenced soon 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 pruning hooks: nation shall not lift up sword against nation, neither shall they learn war any more. (Isaiah 2:4).

Some of the Kings Bay Plowshares Seven are scheduled for sentencing 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 (just as current plans for plutonium pit production there violate EJ), 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 (as well as currently planned plutonium pit production there), 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 (as well as current plans there for such), 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 original plan for which, at Fermi Unit 1 (which suffered a partial meltdown on October 5, 1966), included plutonium generation for nuclear weaponry, and even high-level radioactive waste generation for radiological dispersal devices (also known as dirty bombs). 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, with Georgia right across the Savannah River, 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.

Speaking of Mother Earth, just a month and a half after the 50th anniversary of Earth Day, and just three weeks after Mother's Day, it is good to remember the words of Mother's Day's 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 (as well as current plans for such there), and its commencement at SRS, violates Julia Ward Howe's peaceful vision for the establishment of Mother's Day, and threatens Mother Earth. These plans must be stopped, for the sake of peace, people, and the planet.

Please acknowledge receipt of my comments. Thank you for considering my views and for responding to them in the final EIS.

Sincerely,

Kevin Kamps, Radioactive Waste Specialist,

and Kay Drey, President of the Board of Directors,

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.