the National Nuclear Safety Administration (NNSA)
What (Not) to Do: Deadline is Friday, October 16!
Site Site-Wide Environmental Impact Statement (NTS
NDE Calls for a Broad and Inclusive Scope for the
The deadline is Friday, October
Comments are Submitted to:
Linda M. Cohn
NNSA/NSO SWEIS Comments
PO Box 98518
Las Vegas, NV 89193-8518
Phone (toll-free): 877-781-6105
suggested letter created with the help of the Nevada
Action Network of the
Peace, Justice & Environment Project was available
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.
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
|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
|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
| 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.
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.
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
(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
Bob Ruud Community Center, 150 North Highway 160,
Wednesday, September 16, 5:30-7:30
Tonopah Convention Center, 301 Brougher Ave.,
Friday, September 18, 5:30-7:30
Holiday Inn Conference Center, 850 South Bluff
Street, St. George, Utah.