BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
PO Box 88 ~ Glendale Springs, North Carolina 28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954 ~ Email: BREDL@skybest.com

October 29, 2002

Jay Rose, Document Manager
NA-53, Forrestal Building
US Department of Energy/NNSA
1000 Independence Ave. SW
Washington, DC 20585

Re: Supplement to the Programmatic EIS on SSM for a Modern Pit Facility
Delivered this day at the Public Scoping Meeting in North Augusta, SC

Dear Mr. Rose:

On behalf of the Board of Directors of Blue Ridge Environmental Defense League, I write to comment in opposition to the Department’s proposal to build and operate a new plutonium pit production plant at the Savannah River Site. Moreover, my remarks register our opposition to a so-called modern pit facility at any of the sites proposed by DOE and other agencies.

As you know, plutonium pits are the triggers in a nuclear weapon. "Pits are sealed weapon components containing plutonium and other materials….Pits are surrounded by carefully machined high explosive spheres. When the high explosives are detonated the plutonium is compressed and imploded, thus triggering the nuclear detonation." ¹

Simply stated, the United States does not need more plutonium pits. "The United States is nowhere near experiencing a shortage in plutonium pits. Instead, the United States is awash in plutonium and pits, with a large reserve at Pantex of around 13,000-15,000 pits in addition to the current stockpile of approximately 10,700 warheads." ²

The Department of Energy says aging plutonium pits may be unreliable. But an unbiased expert states, "A purely statistical approach shows that defects in nuclear weapons are historically found to accumulate at a rate of less than 1% per quarter century, implying a characteristic lifetime of more than two millennia for these weapons....Indeed, there is now consensus among specialists that the Pu pits in the US stockpile are stable over periods of at least 50­60 years, with the most recent studies suggesting a far longer period." ³

The purpose of the plant is new nuclear weapons. The Department of Energy admits that no plutonium pit problems due to aging have been identified and that a sufficient number of replacement pits can be manufactured at Los Alamos National Labs in New Mexico. DOE also admits that "the capability being established at LANL will not support...the flexibility to produce pits of a new design in a timely manner." ⁴

Construction of new weapons is illegal. The U.S. Congress ratified and the President signed the Nuclear Non-proliferation Treaty to end the nuclear arms race. The treaty states "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." ⁵

A new plant would encourage the spread of nuclear weapons. Today, the US State Department says, "The Nuclear Non-proliferation Treaty remains the cornerstone of international efforts to prevent the further spread of nuclear weapons. With over 180 parties, it is the most widely adhered to arms control agreement in history. This impressive membership, which continues to grow, is a concrete reflection of the growing international support for nuclear nonproliferation." ⁶

Contamination forced the former plutonium pit plant to close. Plutonium pits were manufactured by DOE at Rocky Flats, Colorado until 1989. Rocky Flats is infamous for thirty-five years of unsafe operations and costly accidents resulting in massive radiological contamination. Plutonium contamination of groundwater was found to be 27 to 135 higher than background levels (Deadly Defense, 1988). The state of Colorado reports: "Independent analyses of soil samples collected near the plant after the fire confirmed that radioactive materials had escaped off-site....On June 6, 1989, agents from the Federal Bureau of Investigation (FBI), the Justice Department and the Environmental Protection Agency (EPA) raided Rocky Flats to investigate allegations of environmental crimes. That same year, Rocky Flats was placed on the EPA's list of Superfund hazardous waste sites slated for cleanup, and the manufacture of plutonium triggers at the plant ceased." ⁷

No new nuclear weapons at Savannah River. CLEAN UP, DON’T BUILD UP!

Respectfully,

Louis A. Zeller
Research Director

footnotes

1. Plutonium: The Last Five Years, http://www.bredl.org/pdf/Last_Five_Years.pdf

2. Jim Bridgman, Program Director, Alliance for Nuclear Accountability, October 15, 2002

3. R. Jeanloz, Science-Based Stockpile Stewardship, Physics Today, December 2000, http://www.physicstoday.org/pt/vol-53/iss-12/p44.html#3

4. Federal Register Vol. 67, No. 184 p.59579, September 23, 2002

5. Treaty on the Non-proliferation of Nuclear Weapons, Article VI, approved by Congress March 1969 and signed by President Nixon November 24, 1969.

6. US Dept. of State, http://www.state.gov/www/global/arms/treaties/npt1.html

7. Colorado Department of Public Health and Environment, http://www.cdphe.state.co.us/rf/historyofrf.htm