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Speak now or for the next five years hold your peace

By       Message Andrew Kishner     Permalink
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The National Nuclear Security Administration (NNSA) has issued its 'Draft Supplement Analysis for the Final Environmental Impact Statement for the Nevada Test Site and Off-Site Locations in the State of Nevada.' The document, released on April 17, is the NNSA’s periodic report on the Nevada Test Site’s Environmental Impact Statement (EIS) that was completed in 1996. Per the National Environmental Policy Act (NEPA), the NNSA must review the 1996 EIS every five years to determine if it is still applicable to current conditions and take into consideration citizens’ written comments on the Analysis that can be submitted at public meetings, by mail or via email. After the NNSA finishes reviewing the written comments the agency will 'determine whether the existing environmental impact statement should be supplemented, a new environmental impact statement should be prepared, or no further [NEPA] documentation is required.'

In the likely event that neither the mainstream media or even Western activists groups have given you a heads up about why a brand-spanking new NTS EIS is desperately needed, let's take a few pointers from Robert Loux of Nevada's Agency for Nuclear Projects who wrote in his September 2007 letter to Stephen Mellington of the NNSA: ‘Since 1996...baseline conditions have changed markedly. It is difficult to see how the...Supplemental Analyses can possibly represent today's known baseline conditions, or how federal officials, using this outdated information, can make informed decisions on future uses and management of the NTS at the landscape.'

The core of Loux's concern - as it should be because of his position with the State of Nevada - is over a dispute between the DOE and the State of Nevada on land issues. Loux contends that current and proposed uses of the NTS should be part of formal consultations with the Department of Interior per language in a 2005 report by the U.S. House of Representatives. After the 1996 NTS EIS was finalized, a number of new ‘uses’ of the test site were initiated. They include: an ongoing subcritical testing program announced in November 1996; various Congressional decisions since 1996 regarding readiness for resumption of underground nuclear testing; and large scale, open air explosive detonations, such as Divine Strake, at locations not previously evaluated and designated for such activities. Loux writes that there is a need for new environmental baselines using data from environmental impacts from subcritical and other testing at NTS since 1996 and that a new site-wide EIS is needed not only for Nevada land issues but also to assess the impacts to humans and the environment.

Loux is right on the money about a lot of things especially Divine Strake. The ‘additional use’ of the NTS for activities such as Divine Strake was NOT addressed in the 1996 NTS EIS. The Defense Threat Reduction Agency (DTRA) and NNSA, if you recall, relied on outdated and non-relevant data from the 1996 EIS to bolster their claims in their sham Environmental Assessments that Divine Strake was safe and posed no radiological dangers. The public, however, didn’t buy it. When, months later, the federal agencies proceeded again down the path to conduct Divine Strake yet failed to provide substantive proof that the testing soils were contamination-free, a storm of public outrage forced the feds to cancel the test.

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Insisting on a new environmental impact statement for the NTS will be the ounce of prevention worth a pound of cure for our future worries, woes and, quite possibly, cancers. The NTS EIS supplement analysis states that DTRA is still pushing ahead and describes DTRA’s Hard Target Defeat Program as an ongoing multi-year effort to evaluate 'alternative capabilities’ using ground and air munitions against tunnels, bunkers and buildings representing different geographic scenarios. The analysis states, 'Tests have been conducted using conventional military munitions in NTS Areas 12 and 16. This is the only activity currently associated with the Defense Threat Reduction Agency Hard Target Defeat Program.' [page 61] Reading between the lines, it is clear that this ongoing DTRA program over the next five years will result in more open-air high explosives testing at the NTS at DTRA’s favorite testing areas, such as Area 16 where Divine Strake was proposed, which were NOT adequately tested for soil contamination in 1996. This should be a major source of worries for downwinders. Why? DTRA and NNSA will, as they did before, justify any and all future open-air high explosive testing without the need for a new NTS EIS, which means there will be NO data on the level of contamination of soils related to these tests. Future use of these Areas [12 and 16] is folly without adequate testing of the soils, which received fallout from Shots Coulomb B, Shasta, Kepler and a number of others. Even tests a fraction of the size of Divine Strake can loft that still ‘hot’ radioactivity into St. George, Utah, or Las Vegas, Nevada. And ‘that’ radioactivity is not as innocuous as ‘eating a banana’ and ‘watching TV’ as one St. George-based pro-Divine Strake commenter once wrote. ‘That’ radioactivity will create a new generation of downwinders.

The process for a new NTS EIS will include scoping meetings, public written/oral comment frameworks and a full discussion of how activities such as subcritical and nuclear simulation testing – and more - relates to the mission of the NTS. This process will be the perfect occasion to bring up the fact that subcritical and nuclear simulation testing at the NTS violates the spirit of test-ban treaties and sends the wrong message – ‘do as I say not what I do’ – to the world community about our non-proliferation efforts. It will also be an occasion to repeat over and over again that the NTS activities – all of them – violate the treaty with the Western Shoshone nation. It will also be an occasion to remind the NNSA that their radiation monitoring network, called CEMP or Community Environmental Monitoring Program, is of third-world quality and doesn’t do nearly a good-enough job at ensuring the safety of people in St. George and Las Vegas and beyond of lofting radiation from the NTS in emergency situations especially large events such as earthquakes or tornadoes.

Considering that the NNSA’s preliminary conclusion based on its draft analysis is to do nothing - and not even complete a supplemental to the outdated 1996 NTS EIS - it is imperative that citizens submit comments to insist (1) that the 1996 NTS EIS does not adequately assess the environmental impacts of future NTS activities over the next 5 years, (2) why it is not valid and (3) that a new site wide EIS needs to be prepared.

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Public comments will be accepted through May 30, 2008 to the address in the following document:

or here

Comments also can be sent via email to nts-sa@nv.doe.gov 

The final supplemental analysis, which will include the NNSA's final action determination, will be issued on Sept. 30, 2008.

The Draft Supplement Analysis is located here: http://www.nv.doe.gov/library/publications/pdfs/Draft_NTS_SA_April_2008.pdf or here

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Andrew Kishner, former webmaster of NuclearCrimes.org, is author of several books about the nuclear age including 'RIG, RAD, RUN: Radiation Monitoring, Fukushima, and Our Nuclear Dystopia.'

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