Comments on DOE/EIS-0573 — Plutonium Pit Production Mission Programmatic Environmental Impact Statement (PEIS)

To: National Nuclear Security Administration
U.S. Department of Energy

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Citizen Action New Mexico submits the following comments regarding the Draft Programmatic Environmental Impact Statement for expanded plutonium pit production.

The Plutonium Pit Production PEIS is ultimately an attempt to justify the unjustifiable. No amount of technical language, charts, or environmental modeling can make expanded production of plutonium bomb cores morally or environmentally acceptable. The document treats large-scale nuclear weapons production as inevitable, while avoiding the deeper question of whether society should continue creating the core components of weapons capable of catastrophic destruction.

The PEIS fails to fully confront the cumulative environmental and public health consequences of expanded pit production. Facilities such as Los Alamos National Laboratory already exist amid decades of unresolved contamination, radioactive waste, groundwater pollution, wildfire danger, and aging nuclear infrastructure. Expanding plutonium operations while these conditions remain unresolved compounds existing risks rather than reducing them. The PEIS does not adequately address the combined long-term impacts of radiation exposure, waste generation, transportation risks, seismic hazards, wildfire threats, and climate-driven disasters across the nuclear weapons complex as a whole.

The PEIS also fails to adequately analyze the full nationwide scope of activities required to support expanded plutonium pit production. Pit manufacturing is not confined to a handful of facilities. It depends upon an interconnected national system involving radioactive material transportation, waste disposal, supporting laboratories, security operations, future cleanup activities, energy and water demands, and long-term waste management across multiple states. The environmental and public health risks associated with those connected activities are not fully analyzed as cumulative nationwide impacts.

The document also minimizes the unresolved issue of long-term radioactive waste disposal. Plutonium pit production generates transuranic waste streams that remain hazardous for extraordinarily long periods of time, yet permanent disposal solutions remain uncertain and incomplete. Expanding production before establishing credible long-term waste management pathways repeats the same pattern that created many of the contamination crises still affecting nuclear weapons sites today.

The accident analysis is similarly inadequate. Plutonium presents extreme hazards when dispersed through fire, explosion, or airborne particles. The risks associated with transportation accidents, facility failures, seismic events, and wildfire-driven releases are not theoretical concerns, particularly in the Southwest where major fires have already threatened nuclear facilities. Climate change further increases these dangers.

The PEIS also fails to adequately confront the environmental justice implications of expanded plutonium pit production. Nuclear weapons activities have historically imposed disproportionate burdens on downwind communities, uranium miners, Indigenous communities, workers, and surrounding populations who often received little warning, little protection, and little meaningful consent regarding exposures and contamination risks. Many of those communities continue to live with unresolved contamination and long-term health consequences today.

The human cost of past nuclear weapons activities in the United States remains staggering. Scientific estimates tied to uranium mining, weapons plants, and radioactive fallout suggest that tens of thousands of Americans may already have died prematurely from earlier nuclear weapons production, with hundreds of thousands more suffering cancers and serious illnesses. The government has never fully cleaned up or fully accounted for that legacy, yet this PEIS proposes expanding the same system that produced it.

The PEIS also improperly narrows the range of alternatives by treating expanded plutonium pit production as a predetermined outcome. The document repeatedly frames its purpose around achieving the “Congressionally mandated rate” of pit production rather than objectively evaluating whether expanded production should occur at all. By defining the mission in advance, the PEIS limits meaningful consideration of reduced production, life-extension strategies, arms control approaches, or other alternatives that could lessen environmental and human harm.

In the end, the PEIS does not resolve these contradictions. It attempts to normalize them. It can estimate contamination levels and model accident scenarios, but it cannot justify the unjustifiable.

Respectfully submitted, May 7, 2026

David B. McCoy, JD, 

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Citizen Action New Mexico