Reading Room

Environmental Lawyers Issue Warning on Plutonium Comb Cores

Tuesday, June 4, 2019

Posted by Marylia Kelley

On behalf of Tri-Valley CAREs, Nuclear Watch New Mexico and Savannah River Site Watch, noted attorneys for the law firm of Meyer Glitzenstein & Eubanks and the Natural Resources Defense Council sent a detailed letter to the National Nuclear Security Administration (NNSA) warning the agency not to expand plutonium pit production without first meeting all legal requirements for timely public review and comment under the National Environmental Policy Act.

Plutonium pits are the fissile cores or "triggers" of modern thermonuclear weapons. The NNSA announced last year that production would quadruple from its currently authorized limit of 20 pits annually to 80 or more pits annually. The plan is to manufacture at least 30 pits per year at the Los Alamos National Laboratory (LANL) and at least 50 pits per year at the Savannah River Site (SRS) in South Carolina.

At LANL, pit production has been plagued with chronic nuclear safety problems spanning a decade. At SRS, plutonium pit production would be an entirely new mission. NNSA proposes to "repurpose" the partially constructed Mixed Oxide Fuel Fabrication Facility at SRS that suffered massive cost overruns before the program was canceled.

The National Environmental Policy Act (NEPA) requires that federal agencies undertake a thoroughgoing environmental analysis of major projects. Moreover, federal proposals requiring implementation over broad geographic areas and long time frames, such as expanded pit production at multiple sites, must be analyzed in a programmatic environmental impact statement (PEIS). Therefore, the attorneys' letter concludes

"... taking a hard look at the expansion of plutonium pit production at LANL and the repurposing of the MOX Facility at SRS, and considering alternatives to this proposed plan, is precisely what NEPA requires. And because NEPA mandates that agencies undertake the NEPA process as early as possible in order to promote informed decision-making, DOE and NNSA must undertake a PEIS as soon as possible.

Until DOE and NNSA fully comply with NEPA through the preparation of a PEIS, any irreversible or irretrievable commitment of resources to either the expansion of pit production at LANL or to the repurposing of the MOX Facility at SRS is unlawful. Accordingly, we request that DOE and NNSA respond to this letter within 30 days to explain when the agencies intend to undertake the required PEIS for the expansion of plutonium pit production at LANL and the repurposing of the MOX Facility for plutonium pit production at SRS."

Accordingly, we expect a response in the coming weeks detailing how the government plans to meet its obligations. Stay tuned!

CLICK HERE to read the 16-page warning letter from the environmental attorneys to NNSA Administrator Lisa E. Gordon-Hagerty.

NOTE: On June 14, 2019 the three groups are sponsoring a public forum on the risks of pit production in Aiken, South Carolina near the Savannah River Site.  The forum will be held in the Aiken Municipal Building auditorium from 7 p.m. to 9 p.m. Tri-Valley CAREs' executive director Marylia Kelley will speak on the link between expanded pit production and a new warhead being developed at Livermore Lab that will require new pits. Kelley will also cover the proposal's impact on arms control and disarmament. For more information about the forum go to: