Nevada Test Site Site-Wide Environmental Impact Statement (NTS SWEIS):
NDE Calls for a Broad and Inclusive Scope for the SWEIS

The deadline is Friday, October 16, 2009

Comments are Submitted to:
Linda M. Cohn
NNSA/NSO SWEIS Comments
PO Box 98518
Las Vegas, NV 89193-8518
Fax: 702-295-5300
Phone (toll-free): 877-781-6105
Email: nepa@nv.doe.gov

An editable, suggested letter created with the help of the Nevada Action Network of the Peace, Justice & Environment Project was available online.

It is very important that the environmental impact of work done at the NTS be viewed in the context of the entire nuclear weapons complex, and not be divorced from the social and environmental problems created by nuclear programs in general. The “scope” of the SWEIS needs to be broad because the damage caused by nuclear development is extremely long-term, and can occur in an instant whether by accident or intention. The environmental harm inherent in the existence and maintenance of nuclear weapons underlies the separate arguments put forward below, and makes these larger issues relevant for the purposes of determining the scope of the NTS SWEIS.

View the letter being submitted by NDE (pdf)
which includes the following points

1. The scope of the SWEIS needs to include the consideration of closing the NTS in its entirety. Nothing in the world can cause as much environmental devastation in as short a time, lasting for as long a time as nuclear weapons. Closing the Test Site would be a concrete, confidence-building sign to the world that the United States will not enlarge or re-shape its nuclear stockpile and is sincere in working for nuclear disarmament.

2. The Western Shoshone National Council should have the final say regarding any of the work mentioned in this message or the SWEIS. The Nevada Test Site land rightfully belongs to the Western Shoshone Nation, and their wishes should be paramount. The Treaty of Ruby Valley (1863) grants their Nation the NTS land and more. Special use by the US military and for other specific uses that have not been negotiated with them are thus illegitimate. The Western Shoshone National Council doesn't support the continued contamination of their land nor its ongoing use for the preparation of nuclear war.

3. Specific proposals included in the SWEIS need to be analyzed for the impact they would have on the prospects for the US to move the world towards reduction and elimination of nuclear weapons. The environmental cost of nuclear weapons is so large as to necessitate its consideration at every turn. Proposed NTS work needs to ensure that it doesn't hinder successful negotiations with other countries and groups to prevent the spread of nuclear weapons. NTS projects must lead the country forward in its obligation to eliminate nuclear weapons from the US arsenal. The Nuclear Non-Proliferation Treaty (NPT) makes any testing of, or improvements to nuclear weapons a violation of international law and hence the laws of the United States. Maintaining our ability to develop new generations of nuclear weapons undermines our moral position as a nation in the face of any other country developing nuclear weapons capabilities. Article VI of the NPT clearly binds the United States (and other nuclear states) to be disarming, not merely promoting non-proliferation.

4. No quantity or quality of environmental education programs like "Operation Clean Desert" with its "Dr. Proton" and "Adam the Atom" justify keeping the NTS open. There is no single polluter that compares with the United States military. Nothing in the world can cause as much environmental devastation in as short a time, with such long term consequences as nuclear weapons. Any educational programs conducted by the NTS or its managers must first and foremost emphasize the toxic impacts of the nuclear complex on the land and lives of nearby people as a warning against further contamination and destruction.

5. If not closed in its entirety, the Nevada Test Site should be closed to all but environmental restoration and containment of material already there. No new hazards or toxins should be introduced to this environment. Specifically, no more low-level or mixed-level waste sites should be opened.

6. At least one of the test shot sites needs to be characterized fully to track off-site drift of contaminants. Over 1000 nuclear detonations have occurred at the NTS already. Monitoring wells upstream of contamination sites can establish a baseline but additional systems are needed around Pahute Mesa and beyond. Evidence of plutonium drifting much faster than expected needs further study. Cumulative exposure also effects other potential uses in and around the NTS.

7. 1.The Comprehensive Test Ban Treaty (CTBT) Organization has the task of monitoring compliance with the CTBT, not the United States, which still hasn't actually ratified it in the Senate. While individual countries have an interest in being able to verify treaty compliance, the United States needs to focus more on taking concrete steps towards disarming than worrying about other countries. Any project such as the Nonproliferation Test and Evaluation Complex (NPTEC) needs to be conducted in support of the International Atomic Energy Agency's (IAEA) mandate to monitor NPT compliance. Given the history of “downwinders” being harmed by fallout from the NTS, the actual safety provided by the NPTEC site's “large safety zone for public protection” needs to be real and substantial. As stated previously, the Western Shoshone Nation needs to approve of all uses of the NTS especially in cases involving introduction of new toxins into the environment.

8. The Tonopah Test Range (TTR) should cease all activities related to R&D and testing of nuclear weapons components and delivery systems as inconsistent with the mandate of disarmament. The same is true for the Joint Actinide Shock Physics Experimental Research (JASPER).

9. No new sub-critical tests should be carried out. Such tests, under the guise of Stockpile Stewardship, undermine US credibility vis a vis the elimination of its nuclear arsenal.

10.The Renewable Energy Option has potential for positive use, but the Western Shoshone should determine what happens at the NTS.

11. The livelihood of workers at the NTS is important, but developing or maintaining nuclear weapons shouldn't be viewed as a jobs program.

The following Letter to the Editor, by Jim Haber, Nevada Desert Experience Coordinator, was printed on Saturday, Sept. 19 in the Las Vegas Review-Journal with the headline, "It's Time to Shut Down the Nevada Test Site." Click here to see the article from Monday, September 14 by Keith Rogers entitled, "Test Site Getting New Life: Center will turn attention to nonproliferation efforts," to which he was responding. For a handout version of this letter with a few other insightful words from allies, click here.

Dear Mr. Rogers and Editors,
   I was enlightened by Keith Rogers' article about proposed new activity at the Nevada Test Site although his tone made many of the ideas and proposals sound like sure things rather than possibilities being "scoped" out by a public process between now and October 16.
   Since the US has been failing to lead the way towards nuclear disarmament, I'm not excited about any enhanced or prolonged activity at the NTS. New sub-critical tests? How does that help us eliminate nuclear weapons?
    International law has been damaged by our support for some regimes with well developed and usable, rogue nuclear programs with deliverable weapons (India, Pakistan and Israel) while making serious threats against other states with far less developed programs and no way to use them (Iran and North Korea). We used the bomb in war and continued to injure and kill tens of thousands of others during tests with little or no apology.
   Who are we to "ensure compliance with treaties" when this administration, like those before it, selectively ignores treaties that are the law of the land? I trust the IAEA and the CTBT Organization to do their monitoring jobs objectively and effectively, more than our government which pursues its own self-perceived interest, and lets allies off the hook while overstating the threat from others, whipping up fear, preventing prospects for peace from germinating.
   No more weapons work at the Nevada Test Site. Or even more, just close it down.
Sincerely,
Jim Haber
Coordinator, Nevada Desert Experience
Organizing Interfaith Resistance to Nuclear War and Weapons
1420 W. Bartlett Ave.
LV NV 89106

How the SWEIS announcement describes the NTS:
NTS is a multi-disciplinary, multi-purpose facility primarily engaged in work that supports national security, homeland security initiatives, waste management, environmental restoration, and defense and non-defense research and development programs (R&D) for DOE/NNSA and other government entities. Historically, the primary DOE/NNSA mission work conducted at NTS was nuclear weapons testing. Since the moratorium on nuclear testing began in October 1992, NTS has been maintained in a state of readiness to conduct underground nuclear tests, if so directed by the President. It also conducts highhazard experiments involving nuclear material and high explosives (HE); provides the capability to process and dispose of a damaged nuclear weapon or improvised nuclear device; and conducts non-nuclear experiments, hydrodynamic testing, and HE testing. Nuclear stockpile stewardship activities at the NTS include conducting dynamic plutonium experiments that provide technical information to maintain the safety and reliability of the U.S. nuclear weapons stockpile, and conducting research and training on nuclear safeguards, criticality safety, and emergency response. Special Nuclear Materials are also stored at the NTS. Also, in accordance with the amended 1996 NTS EIS (DOE/EIS–0243) ROD, NNSA continues to receive low-level and mixed low-level radioactive waste for disposal at NTS. Sandia National Laboratories, a DOE/NNSA contractor, operates the Tonopah Test Range (TTR) near Tonopah, Nevada for flight testing of gravity weapons (including R&D and testing of nuclear weapons components and delivery systems) in support of DOE/NNSA mission requirements.

You can view the entire (about 4 pages) official notice about the EIS and the comment period and meetings from the Federal Register: "Notice of Intent To Prepare an Environmental Impact Statement for the Continued Operation of the Department of Energy/National Nuclear Security Administration Nevada Test Site and Off-Site Locations in the State of Nevada."

Meeting dates, times and locations
(All past. Submit written comments instead.)
Thursday, Sept. 10,  2:00-4:00 p.m. and also 6:00-8:00 p.m., 
Frank Rogers Science and Technology Building, Desert Research Institute, 755 E. Flamingo Rd., Las Vegas, NV.
Monday, September 14, 5:30-7:30 p.m.
Bob Ruud Community Center, 150 North Highway 160, Pahrump, NV.
Wednesday, September 16, 5:30-7:30 p.m.
Tonopah Convention Center, 301 Brougher Ave., Tonopah, NV.
Friday, September 18, 5:30-7:30 p.m.
Holiday Inn Conference Center, 850 South Bluff Street, St. George, Utah.

Contact our Coordinator for more information.

UPCOMING 2009 Events