but it’s good to use your own words. You can submit comments as many times as you like.
This is our chance to say NO to nuclear tyranny!
Ann
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> Dear National Nuclear Security Administration,
lease feel free to use any of the language below, modified as necessary. Comments can be sent to PitPEIS@nnsa.doe.gov Please include document number DOE/EIS-0573 in the email subject line.
Jay
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> I respectfully submit these comments on the draft Programmatic Environmental Impact Statement for Plutonium Pit Production. I am writing on behalf of the Kansas City Chapter of Physicians for Social Responsibility (PSR). I’m a Masters-prepared Pediatric Nurse with a 45 year career protecting children’s health and public health in Kansas City. I also serve on the national board of PSR.
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> I join with thousands of my colleagues across the country in opposing the NNSA’s plans to produce new plutonium “pit” bomb cores for new nuclear weapons in both the Los Alamos National Lab site (LANL) and the Savannah River Site (SRS), as well as the part other sites play, such as the Kansas City National Security (KCNSC) site. My first question is: Why is there not a “No Pit Production” alternative offered? My next question: Why is the number of pits per year increasing? I do not see a valid reason. New pit “trigger” production is provocatively dangerous, unnecessary and expensive. I believe in scientific evidence and demand a rigorous analysis of the risks involved in plutonium pit production across all the sites involved.
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> Nuclear deterrence is a fallacy. It is a cover for preparation for full-on nuclear war-fighting capability. There are 15,000 plutonium pits ready for use at the Pantex site, available should any existing nuclear weapons need them. Making new nuclear weapons is an escalation to a new nuclear arms race. It is throwing gas on the current geopolitical fire of the Russian-Ukraine war, Israel’s genocide in Gaza, and the US war in Iran, all involving nuclear-armed states. We need diplomacy, not more nuclear bombs. What work, if any, does the Department of Energy (DOE) and the National Nuclear Security Administration (NNSA) currently do that helps move the U.S. toward leading the world to global nuclear abolition?
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> Making new plutonium bomb cores for new nuclear weapons flies in the face of the 1970 Non-Proliferation Treaty which was supposed to lead to worldwide disarmament. There are now 100 states who have signed onto the Treaty for the Prohibition of Nuclear Weapons, which became international law in 2021. The US should lead the nuclear-weapons states into joining this treaty. Making new plutonium pits is going the wrong way. Nuclear weapons do not keep us safe; they could end civilization in a matter of hours. Do the DOE and NNSA have any plans or processes to work towards global disarmament in any way? If not, why not? The Department of Energy should turn away from using most of its budget for making nuclear bombs to producing what’s in the title of its Department, that is Energy. And again, DOE is going the wrong way by promoting nuclear energy which harms the environment and our health, instead of promoting renewable energy like wind and solar, which do not foment wars and would help solve the climate crisis.
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> Democracy cannot survive in secrecy. The Department of Energy has been opaque concerning the need for plutonium pits production and its risks to community health and the environment. For example, today Nuclear Watch New Mexico and the Union of Concerned Scientists (UCS) received the FOIA’d “Plutonium Aging Executive Summary (Unclassified) but it was completely redacted. Why was this information hidden? It should be released and another 30 day comment period started as NNSA maintains new pits are needed due to aging concerns. But the 2006 JASON Pit Life Study’s executive summary was released and made fully available to the public. It concluded that most pit types last at least 100 years. Average plutonium pit age is now ~43 years. A 2012 Lawrence Livermore National Lab study found no unexpected aging issues. And can NNSA really guarantee that making new pits for new nuclear weapons won’t lead to deteriorating confidence in these new designs and end up in a push for renewal of (now illegal) nuclear bomb tests? Undoubtedly this would cause world-wide testing to resume.
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> Another local example of this lack of transparency is the KCNSC which was opened in 2014 by a public-private partnership designed to avoid seeking funding from Congress. The city of Kansas City, Missouri’s, Planned Industrial Expansion Authority (PIEA) holds title to the KCNSC and leases it for the federal government’s use. Two years ago when the 15-phase 50% expansion of the KCNSC began, for so-called modernization and plutonium pits production, the public was not well notified and informed of any public meeting or decision-making process. As a matter of fact, our phone calls and emails to the Kansas City authorities were never answered or returned, so we were effectively excluded from the process. Then, during the recent May 7th Kansas City PEIS hearing, an NNSA flier stated that KCNSC is producing 330,000 parts per year for nuclear weapons. This is over three times what had been publicized when the plant opened in 2014. Are these parts similar to the past or are these new parts for plutonium pit production?
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> Given the problematic history of the KC Bannister Federal Complex (BFC) where hundreds, if not thousands, of federal workers in many and various departments were made sick and died from exposure to toxicants used in the KC nuclear bomb parts Plant there, why was the expansion of the KC NSC largely kept from public oversight and comment? It was widely reported in the press during the closing of the BFC that there were about 2,400 hazardous toxicants used at the BFC and that the contamination of the water table below the plant will require pump and treat wells into perpetuity. I believe the Kansas City area should be covered under the Radiation Exposure Compensation (RECA) program for downwinders. What assurances do we have that similar contamination is not happening at the KCNSC? How can the public access information on contamination and worker illnesses or deaths at the KCNSC? I do not see the KC NSC listed on the Department of Labor website showing the number of EEOICP (Energy Employees Occupational Illness Compensation Program) claimants at each site of the nation’s nuclear weapons complex. Why is KC NSC not in this list?
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> The PEIS process has not specified what effects or hazards the plutonium pit production will have on the Kansas City area. What chemicals will be used? Are there any radioactive substances currently used at the KC NSC or will there be any used in the future? What toxicants will be transported in or out of Kansas City? By what means will they be transported – by truck or rail? Will the public be alerted when dangerous substances will be moved in or out of the city? What training will be provided to first responders along transportation routes? What are the risks to the workers at the KC NSC? Have all workers been informed of the risks? Do they have protective clothing and processes in place?
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> The current proposed loosening of radiation limits and safeguards is of particular concern. We need tightened restrictions to protect the most vulnerable among us. Is NNSA aware of the heightened impacts of radiation exposure on women and girls? What analysis has been done of the effects of the relaxation of safeguards on occupational health, on needs for long-term health monitoring, and on impacts on communities that have long borne the burdens of the nuclear weapons enterprise? The RECA program is expiring next year, and a new bill to expand and extend it is to be introduced this week. After spending trillions to make nuclear weapons over the years, is NNSA aware of the billions needed to help those who have suffered and died from cancers and other illnesses over the past eight decades? Has NNSA ever studied the cancer rates around nuclear weapons production sites? If not, why not? If yes, what were the results? The Draft PEIS should thoroughly evaluate the cumulative health risks of expanded plutonium pit production for workers, surrounding communities, and future generations.
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> Cleanup of already existing waste should be prioritized instead of making new bombs with new waste. People around the already contaminated Los Alamos and SRS sites are living with legacy radioactive contamination. The sole repository in New Mexico, the Waste Isolation Pilot Plant (WIPP) is already filling up with radioactive (TRU) wastes. What plan does NNSA have for future radioactive bomb waste? And has NNSA evaluated increased risks due to the climate crisis, such as forest fires and flooding? A known site risk at LANL is a risk of earthquakes. A new “Probabilistic Seismic Hazard Analysis” (PSHA) was to be released early this year; why has this not been released? The half-life of many radioactive substances is thousands and millions of years. The radioactive fallout from over 1,000 U.S. nuclear bomb tests still covers our country and beyond. What policies and processes does DOE/NNSA use to address environmental justice issues at nuclear weapons production sites, particularly for indigenous communities, people of color, low-income folks, and historically marginalized groups? Cumulative radiation exposure increases the likelihood of cancer, heart disease, immunocompromised diseases, reproductive disorders, and inherited genetic damage.
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> We cannot afford this deadly, dangerous and unnecessary pit production scheme. It’s the most expensive program in NNSA history. Plans are to spend $5 billion over each of the next six years and at least $60 billion over the next 20 years. The Government Accountability Office has repeatedly found that NNSA has no credible cost estimates. When will NNSA produce a comprehensive cost estimate and schedule for the pit production program? DOE had ordered a “special assessment” of NNSA’s troubled pit production program due for completion in December, 2025. Why has this not been released to the public? The SRS pit plant will end up being the most expensive building in U.S. history, with a current estimate of $30 billion. How does the NNSA justify this outrageous waste of taxpayer funds when our country is the only industrialized nation without universal health coverage, while the leading cause of bankruptcy is medical debt? It makes no sense.
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> In summary, new pit production is perilous, unwarranted and outrageously expensive. It is a fantastical dream from the Cold War, or rather a nightmare, given the previous Rocky Flats plutonium pit factory fiasco of serious environmental crimes including explosions, fires, leaks, and widespread radioactive contamination. As a health professional, my aim is to first do no harm. It is estimated that radioactive contamination from nuclear weapons production and testing has likely killed more people across the U.S. than the bombings of Hiroshima and Nagasaki. PSR’s credo is “Prevention is the Only Cure” because scientists know an all-out nuclear war would cover the upper atmosphere with the soot from burning cities, resulting in a severe “nuclear winter” Ice Age. The living would envy the dead. That is ultimately why a stringent and rigorous analysis of all risks involved in plutonium pit production, across all the involved sites, is an imperative.
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> Sincerely,
> Ann Suellentrop M.S. R.N.
> Kansas City, Kansas
