BY JAY COGHLAN
Executive Director
Nuclear Watch New Mexico
Three points of possible interest on NNSA’s Notice of Intent for its newly required pit production programmatic environmental impact statement. See https://www.federalregister.gov/documents/2025/05/09/2025-08140/notice-of-intent-to-prepare-a-programmatic-environmental-impact-statement-for-plutonium-pit
1) “NNSA is responsible for management and implementation of the requirements of NEPA, and the regulations and policies promulgated thereunder, including, but not limited to the National Environmental Policy Act of 1969….”
Deafening silence on the fact that it took citizen litigation and a court ruling that NNSA had violated NEPA to compel the agency to begin the programmatic environmental impact statement.
2) “For analytical purposes, this PEIS will evaluate potential impacts over a 50-year period, through approximately 2075.”
This the first I’m aware of this long a time horizon for plutonium pit production. [It is obliquely referred to in radioactive waste issues (see below).]
This is truly a nuclear weapons forever program. New Mexicans can expect LANL to be a nuclear weapons production facility for a very long time. That means more contamination and more radioactive wastes when future disposal paths are not certain.
Related, the relatively recent New Mexico Environment Department permit for DOE’s Waste Isolation Pilot Plant requires prioritization of LANL’s legacy wastes, not freshly generated wastes from plutonium pit production. The WIPP permit also requires DOE to annually report on its search for a new out-of-state WIPP replacement (which will be politically controversial).
In contrast, NNSA says:
“The combined TRU waste (1,151 m3) generated over 50 years would be 57,550 m3, which would account for 53 percent of the projected available capacity at WIPP. In addition, use of WIPP capacity for national security missions such as pit production would be given priority in the allocation.” Final Supplement Analysis of the Complex Transformation Supplemental PEIS, NNSA, December 2019, p. 65, https://www.energy.gov/sites/default/files/2020/01/f70/final-supplement-analysis-eis-0236-s4-sa-02-complex-transformation-12-2019.pdf
It looks like in the future New Mexico and NNSA will at loggerheads on this.
3) “The No-Action Alternative will be based on NNSA’s prior decision to produce 30 pits per year at LANL with surge efforts to produce up to 80 pits per year (85 FR 54544, September 2, 2020).”
Again, a rigged No Action Alternative (like in the draft LANL Site-Wide Environmental Impact Statement). But this does perhaps point to the uncertainty of future pit production at the Savannah River Site, which is facing ever increasing delays and escalating costs. (BTW the pit plant at SRS will be the 2nd most expensive building in human history.) This could boomerang on LANL. The 2019 Defense Authorization Act required “a detailed plan for designing and carrying out production of plutonium pits 31–80 at Los Alamos National Laboratory, in case the MOX facility is not operational and producing pits by 2030.”