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



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