Thursday, July 17, 2025

Comments on yesterday's NRC hearing on LNT and ALARA (July 16, 2025)

To The NRC:

Yesterday the Nuclear Regulatory Commission (NRC) held a huge hearing (about 700 online attendees at its peak) regarding "rethinking" LNT ("Linear, No Threshold") and ALARA ("As Low As Reasonably Achievable"). The hearing was held because of Trump's Executive Order (EO) 14300 Section 5(b) directing the NRC to "reconsider" the LNT model.

Advocates for abandoning LNT and/or ALARA made a number of false and misleading statements, for example implying that people with opposing views think that every radioactive decay will cause cancer. LNT doesn't suggest that, and nobody thinks that way.

More importantly, the NRC's own presenter completely ignored several important aspects of the nuclear fuel cycle and concentrated entirely on the effluent from operating reactors when discussing the potential impacts of keeping, or not keeping, LNT.

Left out were all other pathways for radiation impacts: Mining, milling, processing, transporting, etc., as well as accidents, terrorism and managing/moving the waste... forever.

The inclusion of accidents, terrorism and caring for the nuclear waste for centuries (as most people can now see is virtually inevitable) or millennia (a far more reasonable expectation) is important when considering LNT because all LNT discussions at the meeting were regarding radiation above "background" levels (which, depending on who is using the term, may or may not include man-made radioactive debris from weapons testing and use, or from the thousands of nuclear spills, meltdowns, fires, unintentional (and intentional) releases, and accidents that have already occurred -- many small, but some very large (Chernobyl, Fukushima, Three Mile Island, Santa Susanna, Windscale, etc. Also, more than half a dozen nuclear subs (mostly Russian) have also been lost to the environment).

As several meeting attendees pointed out, the effects at extremely low levels are impossible to measure meaningfully, firstly because "background radiation levels" vary by an order of magnitude or more around the world, and people move, and life-time low-level exposures are extremely difficult to track.

Also because, as mentioned yesterday, about 40% of all Americans will get cancer at some time during their lifetime (I'm ahead of the curve on that score, having had two cancers, one a "solid" cancer (bladder cancer, removed surgically) and one a blood borne cancer (Mantle Cell Lymphoma, removed with chemotherapy).

None of the discussions yesterday considered the effect of "LNT" and "ALARA" on someone like me, who has had perhaps a dozen different highly radioactive medical treatments over the years.

The point is: At extremely low levels, around "background" (whatever that means), SO WHAT if Hormesis really is a thing! (Not that there are any serious indications that it is.) But for those so sure it is, let them take a "sunshine pill" of strontium (for their bones, I guess) every day if it makes them happy! There's certainly plenty of radioactive waste to spare.

Using "background levels" of radiation as the standard dosage, above which there might -- or might not --be harm might be appropriate for some people. But millions of us get far more radiation (at least at some point in our lives). People living near Chernobyl. People living near Hanford, Washington, or West Valley, New York, or Rocky Flats, Colorado, or downwind of the Nevada Test Site.

And people like me.

When we're NOT talking about "background levels" of radiation, it's a GIVEN that higher radiation doses increase the risk of cancer. This is indisputable, and as an example, my personal risk factors are already increased by the radiation treatments I have received, from tooth x-rays (well known to be less-than-harmless) to CT-SCANS and PET scans and whatever else the doctors ordered. But my other choice was basically premature death -- and cavities.

When it comes to nuclear power, there are many other choices. There are better ways to generate electricity. For instance, a distributed system such as rooftop solar is far more resilient and NEVER poisons the earth with a meltdown.

During yesterday's meeting, LNT and ALARA were only considered regarding the amount of nuclear material that can be released from operating reactors, NOT from the clear and present danger ANY increase in radiation causes to individuals like myself, which includes tens of millions of Americans, if not hundreds of millions. And also not considered were additional radioactive doses from the lifecycle of the nuclear material, the potential for catastrophic accidents or terrorism, acts of Mother Nature, etc..

As noted by scientist Mary Olson during yesterday's NRC hearing, radiation protection limits are based on "reference man" who is a theoretically constructed healthy adult male.

Not a woman. Not an infant. Certainly not a fetus. And not a cancer survivor.

Also excluded from any discussion by the NRC or any pro-nuclear speakers during the hearing was the FACT that nuclear "waste" is PRODUCED by nuclear power plants: That is, uranium straight out of the ground is not nearly as dangerous as the witch's brew of fission and activation products created by nuclear bombs and nuclear reactors. Besides, if left in the ground, uranium tends to stay there. After a meltdown, it (and its fission and activation products) go everywhere.

In a word, the main product -- the main output -- of the nuclear industry is nuclear waste, NOT electricity -- that's just a fleeting byproduct.

This is, in fact, why commercial nuclear reactors were constructed in the first place: To produce plutonium for bombs, which instead became nuclear waste along with all the fission and other activation products produced along with the plutonium.

Some of the most common fission products created by nuclear reactors (or nuclear bombs), such as strontium, cesium and tritium, mimic useful atoms in the body until the moment they decay. A rough estimate is that, pound for pound, used reactor fuel is about a million times more hazardous than "fresh" reactor fuel that has never been in a nuclear reactor, never undergone criticality.

So it's fair to say that the main product produced by nuclear reactors is highly toxic nuclear waste.

After 80 years of splitting atoms for one reason or another, there is still NO solution to the waste problem -- other than the proposal to truck it into a tunnel on stolen Indian land somewhere. Yucca Mountain was assuredly that place for nearly a quarter of a century before it was abandoned for mostly geological and engineering reasons, along with enormous political opposition -- opposition ALL such places will get if America EVER gets close to choosing a destiny for its growing, glowing nuclear waste pile.

Producing nuclear waste is a crime against all future living things. Plutonium and many of the fission products of nuclear reactors either do not exist in nature or are so extremely rare as to make even the rarest of the so-called "rare earth" elements seem positively plentiful in comparison. Many of the man-made radioactive products do not behave chemically anything like "background radiation" (external vs. internal or even bone-seeking, for example).

Another problem with simply looking at LNT as it pertains to the damage it causes versus any supposed benefit it might have for society is that the person harmed is rarely the one who benefits -- which is unfair. It might be someone a thousand years hence who is harmed by the radioactive waste produced today, which was used to light a light for one fleeting moment of time.

Nuclear-generated electricity has never been anything close to "too cheap to meter" and instead is, was and always will be the most expensive form of energy ever devised -- but much of the payment -- in cancer, leukemia, and other illnesses -- is deferred to others, later in time and place.

Those harmed will not be able to identify the assailant who harmed them, which will be us -- this generation -- but we will all be long dead many generations ago. The poisons we produced in nuclear reactors today will still be harming others, generations from now.

Renewables can easily replace nuclear power and are cheaper, cleaner, safer, and pose no threat from terrorism or anything else. Small accidents, certainly. Those can happen at a wind farm or anywhere else. But no other energy source besides nuclear can render "an area the size of Pennsylvania" uninhabitable from ONE SINGLE ACCIDENT. Only nuclear can do that. And nuclear WILL do that, again and again, until we shut them all down.

So: LNT or not (and even if Hormesis is a thing) there is no doubt that large doses of radiation from accidents are inevitable -- along with smaller doses to large populations and tiny doses to huge populations of people and other living things.

LNT and ALARA (or Hormesis, for that matter) never has accounted for those inevitable accidents. Japan thought it couldn't happen there. Russia thought it couldn't happen there. England thought it couldn't happen there. And here in America we keep beating our heads against the wall, pretending it won't happen AGAIN here.

It will.

LNT is only a statistical model -- an approximation. Flaws -- real flaws -- in its basic assumptions can appear to make other approximations make sense if you pick and choose your data carefully (that is, poorly, or selectively) enough. For example, nuclear plant workers are generally well-paid, have good health care, and retire early compared to many other people. They are an unusually healthy cohort. Their higher allowable radiation doses are rarely exceeded or even approached, so there is essentially no reliable data from them. And there is enormous incentive to hide data by the corporations involved.

The most reliable data available (such as it is: More studies still could be done and have been proposed) indicates that LNT is a good approximation. It also indicates that Hormesis is a dream of the nuclear industry, and that the current standards should be tightened, not loosened in any way. Too many inevitable events are ignored.

Ace Hoffman, Carlsbad, California USA

The NRC will continue to take WRITTEN comments (no deadline, but ASAP is better!) at these emails:

ed.Miller [at] nrc.gov AND david.Garmon-Candelaria [at] nrc.gov



Contact information for the author of this newsletter:

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company



Sunday, June 1, 2025

Mad Science: The Nuclear Power Experiment

Copyright 2012 by Joseph Mangano, MPH, MBA

Book Review by Sharon and Ace Hoffman, May 2025

Mad Science is a compelling read, and highly recommended for its clear explanations of data relationships and the statistical methods available to quantify low-level radiation damage.

Mangano highlights the many lies that have been used over the years to justify building and operating nuclear power plants -- edifices which produce thousands of tons of highly toxic nuclear waste that lasts for eons -- along with a few decades of very expensive electricity.

Mangano is an expert on the health impacts from nuclear power. In 1989 Mangano led a study which measured radioactivity in children's baby teeth who lived near nuclear reactors. That study was modeled after the famous 1960s Baby Tooth Survey, which helped convince President John F. Kennedy to pressure the Soviets to jointly ban above-ground testing of nuclear weapons -- a ban that has stood the test of time.

Mad Science was published in 2012, the year after the Tohoku Earthquake & Tsunami.* Mad Science begins with a synopsis of the history of nuclear power and its inextricable connection to nuclear weapons. Throughout the book, Mangano presents extensive data and statistical analysis indicating that nuclear power has never been safe, reliable, or cost-effective, and that the risks have never been properly presented to the public.

Mad Science points out that communities near reactors are continually exposed to radiation because “every reactor must routinely emit a portion of the radioactive particles and gases it produces.” (p. 25)

Additionally: “[nearly] all high level waste remains … at each nuclear plant …”. (This is still true as this review is being written (2025) and will be true for the foreseeable future.)

As a case study, Mad Science takes an in-depth look at the legacy of the troubled Santa Susana site near Los Angeles, California. Santa Susana has had multiple corporate owners but the original project was a joint venture between Atomics International and Southern California Edison (SCE). The Sodium Reactor Experiment (SRE) at Santa Susana "went critical" for the first time in April 1957 and melted down July 12, 1959. Decades later, communities near Santa Susana began questioning the many birth defects and cancers in their neighborhoods, including rare childhood cancers.

A former Santa Susana employee stated that after the SRE meltdown, film badges were taken away -- because management knew “…levels would be really high.” (pg. 106)

In contrast, company officials issued an internal report six weeks after the meltdown stating that: “…operating personnel were not exposed to harmful conditions.” (pg. 105) The internal report was shared with the Atomic Energy Commission, but was not published.

Mangano searches for the truth behind these conflicting versions of history by analyzing statistics comparing the incidence of cancer and birth defects in communities near Santa Susana with several communities with similar characteristics (populations, physical area, etc.) elsewhere in California.

Although Mad Science was published more than 10 years ago,the federal Nuclear Regulatory Commission continues to extend licenses for aging nuclear power plants -- just as Mangano predicted -- and advocates of nuclear power continue to peddle the myth that nuclear power is safe.**

Mangano explores the attempt to reprocess nuclear fuel at West Valley, New York, which opened in 1966 and "failed dismally," closing just six years later and leaving behind: “…enormous amounts of used fuel assemblies, liquid waste, solid waste, and low-level waste. … West Valley remains a large, dirty burial ground for high-level nuclear waste.” (pgs. 197-198)

The history of unsuccessful experiments with sodium-cooled reactors, including Santa Susana, seems particularly prescient now, in 2025, as the nuclear industry attempts to bypass regulations and legislation by promoting Small Modular Nuclear Reactors (usually called SMRs instead of SMNRs to hide the word Nuclear) -- including sodium-cooled SMNRs -- as "safe" (they aren't), small (they aren't) and green (definitely not that either!).

Mangano's book helps uncover the many unsavory secrets of nuclear power.

Review written June, 2025 by Sharon and Ace Hoffman

In the 1990s the authors of this book review worked with Ace's father to produce a first-year interactive computerized college course on statistics (available free online). The elder Hoffman, the late Dr. Howard S. Hoffman, an experimental psychologist, had taught thousands of students statistics for nearly half a century at Pennsylvania State University and Bryn Mawr College.

The book review is available online at https://acehoffman.blogspot.com/2025/06/mad-science-nuclear-power-experiment.html

* Also known as the Great East Japan Earthquake, Tohoku is blamed for causing the triple meltdowns at the Fukushima Daiichi Nuclear Power Plant in Japan. But really, it was mankind's hubris that caused the meltdowns. Ancient stone markers in the hills behind the plant warned of the potential high height of tsunamis in the area; the signs were ignored. Whistleblowers warned that the type of reactors at Fukushima Daiichi were unsafe (General Electric Mark-1 Boiling Water Reactors (BWRs)); the whistleblowers were ignored. Warnings about the design of the Emergency Diesel Generators were ignored. Warnings about the design of the spent fuel pools, directly above the reactors themselves, were ignored. (All these problem are still ignored at nearly two dozen similar reactors in the United States.)

** Yet the reactors themselves are becoming more and more embrittled, maintenance is often lacking or inadequate, wiring diagrams have long since disappeared or don't match the current arrangement after decades of repair and reworking (such as computerizing the control room), and in all likelihood, no one working at the reactor now was even out of high school when the reactor was designed and built. How old are these reactors? Before San Onofre decided to close permanently, someone thrust a pencil through the side of the fuel tank for one of the emergency backup diesel generators. Presumably, this was NOT "terrorism" or "sabotage" it was an attempt to force repair or replacement of the badly rusted part (the reactor was not operational at the time).

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Contact information for the author of this newsletter:

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company



Sunday, May 25, 2025

It's The Pits: Plutonium Pit Production Programmatic EIS “Scoping” Comments needed by July 14, 2025!

Dear Readers,

Plutonium pits are the core of nuclear bombs. Literally: They start the explosion.

Theoretically, the pits can last at least a hundred years. (The nuclear era isn't nearly that old.)

America has several thousand pits installed in nuclear weapons that are ready to be used at a moment's notice. On submarines, in missile silos, and constantly loaded on bombers.

More than 15,000 pits have already been built. The last thing we need is more cores to store for evermore. Making new pits is an extremely dirty process. The poison the pits are made of -- Plutonium -- has a half-life of about 24,100 years (only to decay into various other radioactive poisons). Old pits have to be actively cared for -- or carefully stored somehow -- away from prying eyes and terrorists -- essentially for eternity.

Nevertheless, the National Nuclear Security Administration (NNSA) plans to manufacture MORE pits, at enormous cost and risk. However, one thing is standing in their way: The NNSA failed to complete the required nationwide "programmatic environmental impact statement" (PEIS) for what will become its most costly program ever: The expanded production of plutonium pits.

Fortunately, Nuclear Watch NM, Savannah River Site Watch and Tri-Valley CAREs successfully sued the National Nuclear Security Administration (NNSA) over the NNSA's failure to complete the PEIS as required by the National Environmental Policy Act.

To meet its enforced legal obligation, the NNSA is holding virtual "scoping" hearings next week (Tuesday, May 27, 2025 and Wednesday, May 28, 2025). Written submissions will be accepted until July 14, 2025. Below is the letter I plan to submit to the NNSA opposing Pu Pit production. Below that is some additional information from nukewatch.org

Ace Hoffman, Carlsbad, California USA (images added for the online version)


To: National Nuclear Security Administration

Re: Programmatic Environmental Impact Statement (PEIS) for the production of plutonium pits

To the NNSA:

I wish to state my strong opposition to the production of plutonium pits, to the refurbishing of old plutonium pits, and to the continued maintenance of a massive nuclear stockpile. Regarding the eventual PEIS that must be created: The PEIS needs to include a rigorous analysis of the risks associated with plutonium pit production across its many sites. This must include EVERY reasonably possible risk, from the dangers to the public from radioactive releases into the local and global environment, to the costs being so high they seriously impact other, better, uses of limited funds (such as for fire trucks: The entire nation is short thousands of modern fire trucks), to the potential that the pit production sites would themselves become targets for espionage, sabotage, terrorism, accidental airplane strikes, or even nuclear attacks. In addition, as discussed below, the PEIS should consider if there is ANY necessity for ANY additional nuclear warheads, and thus, for any new or refurbished pits at all, as well as considering the environmental, medical, political and financial effects of the USE of these weapons.

The NNSA claims that they are "required to produce 80 new pits per year." As I show below, nuclear weapons are illegal, and therefore any "requirement" to produce nuclear weapons is an illegal order.

Since the 1970s I have felt that the maximum number of nuclear weapons the United States needs to have available to ensure adequate DETERRENCE capabilities is VASTLY LESS than the current stockpile.

My estimate has always been a maxinmum of seven (if any). I cannot precisely justify it, but it has never changed since I was first reading about nuclear weapons in the 1970s. It did not change when I corresponded by phone and postal mail with Dr. John Gofman, from LLNL and the Manhattan Project, who also did not think "zero" was practical but agreed there were far too many nuclear weapons back then as well.

It did not change when I spoke via phone with Dr. Karl Z. Morgan, also from the Manhattan Project and founder of the Health Physics Society, about the dangers of Low Level Radiation.

It did not change after I learned about tritium from Dr. Marion Fulk, also from LLNL and the Manhattan Project. With his help and at his suggestion, we designed a new Electromagnetic Wave Spectrum chart that includes a third row that is missing from nearly all such charts, showing the Energy Equivalent values.

Nor did my opinion change when I learned about the health aspects of nuclear war from such experts as Ernest J. Sternglass, Rosalie Bertell, Judith Johnsrud, Arjun Makhijani, Arnie Gundersen, Richard Webb, Joe Mangano, Helen Caldicott, Jack Shannon, Stanley Thompson, Chris Busby and dozens of others.

Nor did it change when the U.S. Government, through a third party, purchased my software source code for sequencing images with text, joysticks, mouse, keyboard and lasers (all at the same time) in the late 1980s and early 1990s. Around the same time, EG&G purchased my animation toolkit and -- much later -- I learned what EG&G does at Area 51. (Yesterday, to be precise.)

Nor did the number change when I read my own father's history of his experiences during World War Two, co-written with his historian wife, my step-mother. His company came upon Malmedy. They came upon barns where hundreds of Jews had been burned alive (see photos in their book). His company also took part in the relief of Bastogne. The bombing of Cassino in Italy was my father's introduction to combat (as part of a mortar company they fired last, since they were the closest artillery to the enemy position). That was before D-Day in France.

And I have not changed my opinion after two cancers, two strokes, four seizures and a minor heart operation (all but the first cancer in the last five years).

Seven nuclear weapons. At most.

I also do not believe there is any need for dozens of nuclear-powered submarines: There is no safe way or safe place to store the waste they generate, just as there is no safe way or safe place to store the waste from so-called commercial reactors. And more and more sensitive equipment is making nuclear submarines virtually impossible to hide anyway, because of the gamma rays and radioactive trails they emit, despite all the shielding and filtering.

But why such a low number? Not even seventy?

No. Definitely not!

There are several reasons. The first and most important is that modern warfare is more and more becoming a battle of wits and swiftness rather than merely strength and endurance. Most key moments in modern warfare occur in brief bursts of energy and/or anger: The attack by Hamas on Oct 7, the January 6 DC riot, the exploding pagers by Israel. Russia's initial phase in Ukraine was sudden, unexpected, and was preceded by numerous lies about the reason for a buildup near Ukraine's borders. 9-11 was sudden, severe, and was intended not only to inflict massive pain and suffering (which it did) but was also undoubtedly intended to show that far worse could have been done...with nukes. Suitcase-sized, for instance. Or on business jets, such as the Cessna Citation.

We will NEVER be rid of the THREAT of a nuclear attack, as long as nuclear materials are available on the black market (which they have been for years), or are lost in quantities that can be turned into a bomb (ditto), or are obtained/created/extracted by a rogue nation (ditto).

Assuming such an attack CAN happen leaves only two questions: How best can we avoid it? And how best can we detect it if it's coming?

The answers to both questions require a severe REDUCTION in America's nuclear capacity, which will, of course, need to be negotiated with Russia and China and several other countries, but mainly with those two. I'm sure they don't really like spending the money, either, and I'm sure they also know that MAD (Mutually Assured Destruction) is a complete failure as a policy and as a deterrent. It's something nobody wants.

But about the money. The nuclear industry and the nuclear weaponry have BOTH been a fiasco (call it what it is). Just look at the price of solar rooftops (they're going through the floor, price-wise!). Look at the capacity for wind power across the nation. Look at the number of times ANY nation has chosen to resort to nuclear weapons during war. Precisely twice, of course. Why? Because OF COURSE every nation is afraid to uncork that bottle! Even Israel won't use them on Gaza (or at least hasn't as of this writing) -- though surely their goal there (lofty or evil, see it how you want for the purposes of this discussion) could have been accomplished in an instant if they had used a few nukes. So why haven't they?

One reason is surely the fallout that would result. And I'm not talking about the political fallout. I mean the real fallout. No sane country would EVER want to use these weapons where the radioactive dust would blow over them, too. Or where it would blow over their troops, if they can help it.

America knows this because we've tested nuclear fallout on hundreds of thousands of American soldiers and the results were cancers, tumors, and all manner of other health problems among atomic veterans (we interviewed several surviving atomic veterans at the Atomic Testing Museum many years ago; those interviews are available online).

All told, the nuclear industry and the unusable nuclear weapons have robbed the world of tens of trillions of dollars that could have gone to building universities, building solar rooftops, feeding the poor, developing better and better vaccines, fighting (instead of enabling) cancer... we even could have been equipping American soldiers in Vietnam with better weapons instead of the cheaper solution of having them spread Agent Orange around the jungle. But we were spending billions of dollars on blowing up dirt in the desert, since atmospheric testing had been banned. For what? For a bunch of large holes! (Years ago I flew over the Nevada Test Site...that's what it looks like: Not unlike the moon.)

That's NOT what we want for the whole world! We don't need new pits. We need better thinking.

Besides: What proof is there that the current scourge of nuclear weapons isn't far more than "sufficient"? What proof is there that these weapons have aged poorly? What proof is that there aren't better uses for the money? Uses that are more likely to bring peace around the world and specifically for America. Fund USAID at ten times its previous level, for example.

The money could even be better spent looking for spies, traitors, infiltrators, useful idiots, and saboteurs who hide behind cloaks of American flags, hats, Artificial Intelligence-generated personalities, and Regular Joes who are actually cult members ready to attack on command, not even knowing what they're really being asked to do or who is asking them. Some useful idiot who thinks they are patriotic might launch a missile, thinking they were secretly told to do so by the President, but actually it was an AI hallucination.

How does having to protect entire industries that don't benefit humanity in any way, help protect us from the real threats that have resulted in everything from 9-11 to the assassinations and attempted assassinations of Presidents?

In a worst-case scenario, how does a nuclear response to a nuclear attack bring peace, rather than a further nuclear response and endless misery? What mechanism stops a nuclear war once it has started? Surely not more bombs to use!

And is it fair to attack a non-nuclear nation with nuclear weapons?

Under these circumstances, a first-strike seems totally out of the question. But so does a nuclear response, because, after someone else does a "first strike," the whole world is back at "ground zero." To retaliate against a lone nuclear strike with overwhelming nuclear force would be MADness, but to retaliate with a same-sized response almost guarantees a return volley!

And using nuclear weapons against the citizens of a dictatorship would simply be adding cruelty to people already suffering from being in a dictatorship. That's no way to help free them!

And it may be very difficult to know who actually attacked us. Nuclear weapons don't leave much of the source material to track back to their definitive creator. And there's even a good chance that whoever does it might want to make it LOOK like some other country, or terrorist group, did the dirty deed.

We have many other non-nuclear options -- including some very large bombs -- which are designed for targeted strikes. We have incredible accuracy and reliability thanks to multiple satellite-based geolocating systems, each system backed up by multiple satellites. (But so does everyone else.)

Causing massive numbers of civilian casualties is against international law and common decency. Destroying the environment is too. And such actions invite -- perhaps even demand -- reprisals. Sometime, somewhere, by someone.

A lasting peace is in everyone's best interests. Our enemies -- everyone's enemies, on every side of every major conflict and many minor ones -- can have access to nuclear weapons, chemical weapons, biological weapons, laser weapons, AI weapons and massive propaganda weapons too, just as we have. Maybe not as good -- but maybe better. Our enemies won't tell us what they've got until they are ready to use it.

Some of these sources of misery -- the weapons, the chemicals and so on -- even the most malicious actors have stayed away from. Thank goodness. But it's time for nuclear weapons to be permanently added to that group of weapons that are considered far too evil to contemplate using. There are too many targets (such as nuclear power plants and spent fuel installations), too many innocent people everywhere, too many generations yet to come, who should not have to suffer for our mistakes, our squabbles, our fights, or our stubborn foolishness.

It's the pits. We don't need more pits.

Ace Hoffman, Carlsbad, California USA

Here is a video of my "three minutes of fame" (speaking at the second NNSA PEIS hearing on Wednesday, May 28, 2025):

Electromagnetic Wave Spectrum image:

Low Resolution Version:
https://acehoffman.org/images/2025/Code_Killers_Pg9ElectromagneticSpectrum20210422A_8bit50pct.png

High Resolution Version:
https://acehoffman.org/images/2025/Code_Killers_Pg9ElectromagneticSpectrum20210422A_24bit100pct.png

Interviews with Atomic Veterans:
https://acehoffman.blogspot.com/2015/11/new-videos-oral-histories-and.html


Dear Friends,

On Tuesday and Wednesday, May 27 & 28, the public is offered a rare public forum to comment on the environmental impacts of nuclear weapons and nuclear weapons production. See below for links to virtual hearings being held from 5-7:30PM EST

Background: In 1989, the FBI raided and shut the U.S. Department of Energy's (DOE) Rocky Flats plutonium pit bomb factory in Denver, CO, effectively shutting down the U.S. Cold War machine. Over the next couple of years, the Berlin Wall came down, the Soviet Union dissolved and the U.S. declared that it would convert the nuclear war economy to invest our new "peace dividend." An Office of Environmental Management was set up to address the Cold War contamination at the nation's bomb factories, including at Savannah River Site (SRS) on Georgia's border. Daily revelations of the extent of environmental damage, including 35,000,000 gallons of highly radioactive liquid waste from plutonium production in antique underground tanks at SRS, shocked the nation. The main contractor at Rocky Flats was convicted of criminal misconduct because of all the plutonium fires, explosions and contamination. These are only a couple of the high costs of U.S. nuclear domination.

In 1991, however, DOE began the first of its attempts to reassemble its crumbling nuclear weapons manufacturing complex and proposed to manufacture plutonium pits at SRS as part of its COMPLEX 21 vision. Activists were trained in using the powerful Environmental Impact Statement (EIS) process, a two-part public information gathering process mandated by the 1970 National Environmental Policy Act (NEPA). NEPA requires any agency or company to analyze all foreseeable environmental impacts before approving any major projects. In the days before the internet, we called, mailed, or traveled to Aiken, SC, to give comments about what the scope of the EIS should be, then called, mailed, or traveled again to comment on the draft EIS that was published following scoping. Flash forward —>> WE WON!

In 2008, DOE came back with COMPLEX TRANSFORMATION which activists dubbed BOMBPLEX. Many of you participated in the "Hunt for Weapons of Mass Destruction" bus trip to Augusta, GA, for public hearings organized by Georgia WAND.  Flash forward —>> WE WON AGAIN!!

But of course, in 2019, DOE was b-a-a-a-c-c-k-k-k AGAIN with an ill-advised proposal to convert the failed MOX factory (WE WON THAT TOO!) to, you guessed it, a plutonium pit factory. So, we commented on scoping awhile back before COVID, but this time, several groups (see below) sued the DOE's National Nuclear Security Agency (NNSA) (which got created along the way by DOE to add a layer of secrecy and further confuse the public) saying that the EIS they were undertaking was fundamentally insufficient because it needs to perform a PROGRAMMATIC EIS because the plutonium pit enterprise would involve transporting plutonium across state lines as well as exporting radioactive waste. THEY WON!!!

SO HERE WE ARE. You have two opportunities on Tuesday, May 27, or on Wednesday, May 28, to tell The Man we have outgrown nuclear weapons and are ready to build our peaceful future! See below for pertinent info and talking points.

NUCLEAR WATCH SOUTH'S BASIC POSITION is this: NEPA requires that ALL environmental impacts of the proposed project be analyzed. HELLO. The plutonium pits proposed to be manufactured at SRS are the explosive trigger of every nuclear weapon. The environmental impact of using the proposed product, a plutonium pit, is ENVIRONMENTAL DESTRUCTION! Pure and simple.

NEPA also requires analysis of alternatives to the proposed project. And so Nuclear Watch South says, SAY IT LOUD, the environmental impacts of pursuing nuclear disarmament must also be analyzed in the Programmatic Environmental Impact Statement.

Thanks to our friends at Peaceworks Kansas City for compiling the fact sheet below. In addition to the two nights of public hearings, the deadline to email comments is July 14. Email PitPEIS@nnsa.doe.gov

Download the Federal Register Notice here: https://www.govinfo.gov/content/pkg/FR-2025-05-09/pdf/2025-08140.pdf

 

Suggested scoping comments are available at https://nukewatch.org/pit-scoping-comments


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Ace Hoffman, Carlsbad, California USA

rhoffman@animatedsoftware.com





Contact information for the author of this newsletter:

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company