Talking Points


TEST SITE FUTURE VISION TALKING POINTS ABOUT ENVIRONMENTAL IMPACTS


THE SITE-WIDE ENVIRONMENTAL IMPACT STATEMENT (SWEIS) AND THE COMMENT PROCESS

The federal government is weighing the ten year future of the former Nevada Test Site, (now called the Nevada National Security Site), including programs that require transportation routes all over the United States. Possible programs range from alternative energy production to national nuclear waste disposal to weapons development and test firing. The issues are complex and interesting, and public participation in decision-making is very important. You and your family, the environment and the economy will be affected. Public comment meetings were held in late September.

Written comments can be submitted until December 2, 2011:

• By mail to Linda Cohn, NNSA/NSO SWEIS Documents Manager, PO Box 98518, Las Vegas NV 98518

• By fax at 702-295-5300 or Online at http://nnsa.energy.gov/nepa/nnsssweis/comment 

HOME has prepared the following SWEIS Talking Points guide after extensive study of the documents by a team of experts on a range of issues. We offer these for anyone to use in submitting their own comments. Please share widely.

Our thanks to DOE for extending the comment period into December to allow reasonable and thorough responses. 

This comment process is a welcome opening and an important opportunity for the public to help fundamentally change the direction of activities at the Nevada Test Site (now called the Nevada National Security Site, or NNSS). We also appreciate the inclusion of the positions of the Consolidated Group of Tribes and Organizations that are clearly outlined throughout the SWEIS document, and hope that the Department of Energy (DOE) will be guided by them. We do believe that the Dept. of Energy (DOE) should identify their Preferred Alternative, as it is more difficult to analyze the SWEIS without a clear sense of the DOE’s priorities. It should be noted that DOE did not state preferred alternatives in 1996, but later chose the Expanded Ops Alternative in every program. 

The SWEIS structure does not provide adequate information about current environmental impacts. 

The reader needs to know all of the enormous impacts of past and current Test Site activities to the soil, water and air quality in order to quantify what “more” or “less” activity as defined in the SWEIS would really mean. 

Cross program analysis and cost data is needed to understand and evaluate priorities. 

The SWEIS should provide enough financial budget information for the reader to evaluate the significance of specific programs, both within the Test Site mission, and relative to our economically devastated nation as a whole. There is no data in the SWEIS that shows the resource allocation in cost for of each of the programs. For instance, the public has no idea what costs are incurred for the various Stockpile Stewardship experiments, or for environmental restoration projects. The SWEIS under the National Environmental Policy Act (NEPA) should provide sufficient information for an evaluation of the alternatives, and to determine whether there is an alternative that still needs to be considered, and whether a dropped alternative is justified. 

SITE-WIDE LAND USE ISSUES 

Whenever possible, new lands should not be disturbed. 

Dangerous areas should also not be disturbed. The Nevada desert and its inhabitants are slowly healing from over 60 years of immensely toxic and destructive human activities. Whenever not toxic to employees and others, all activities, trainings and installations should be conducted on previously disturbed lands. Undamaged land and endangered species habitat should be protected. Conversely, care must be taken to minimize disturbance where below-surface contamination would be exposed. 

Safe groundwater standards must include the needs of all living species at the Test Site. 

The document states that contaminated groundwater is acceptable, since human beings can buy bottled water.

Shoshone and Paiute land rights, access and inclusion in decisions must be respected. 

HOME continues to insist that the U.S. follow federal and international laws in upholding the Western Shoshone Treaty of Ruby Valley, ratified by Congress in 1863. Additionally, Shoshone oppose any further ground disturbance on their treaty lands. Whenever safe, access to sacred, cultural and resource sites must be provided for traditional Native use. Tribal entities must be included in land and resource management, including historic and cultural resources. 

TEST SITE DEFENSE MISSION –
WEAPONS TESTING, DEVELOPMENT & DISMANTLING 


Nuclear weapons programs should continue to be scaled back until eliminated completely. 

The SWEIS states "The primary purpose of continuing operation of the [Test Site] is to provide support for NNSA's nuclear weapons stockpile and stewardship missions." However, these activities have been declining in recent years, and this downward trend should continue or increase. Congress has repeatedly rejected paying for new nuclear weapons designs and expanded plutonium pit production, and there has been much public discussion recently about the U.S. adopting the long-term national security goal of a nuclear weapons-free future. Further environmental damage and federal expenditure on nuclear programs is inconsistent with that goal. However, verification of compliance with international weapons treaties and reducing and dismantling aging U.S. arsenals is important, and consistent with U.S. goals. 

Expanded explosives testing and release of dangerous contaminants should not be considered. 

No resumption of nuclear or any other explosives testing should be considered, until previous contamination to soil and groundwater is fully characterized, mapped out and thoroughly analyzed. The Reduced Operations Alternative, which would disturb the soils, plant life, wildlife and surface drainage of only 430 acres for “explosive”, “dynamic” and “biological” experiments, is far preferable to Current Operations at 700 acres, or Expanded Operations, which would disturb 3,335 acres.120 additional acres should not be destroyed by the use of Depleted Uranium (DU) munitions. DU is proven to cause significant health problems worldwide, especially among children, and its use should be banned. Contamination from biological warfare experiments of training is completely unacceptable. 

ENVIRONMENTAL MANAGEMENT MISSION - NTS RESTORATION 

A primary emphasis must be to fully characterize historical contamination and seek clean-up actions.

 The amount of contamination at the Nevada Test Site and off-site locations (NTS) from the overt nuclear testing period 1952 to 1992 is enormous. Estimates of the extent of manmade radioactive contamination are on the order of 2,000 – 3,000 curies in the soil and 130 million curies in the groundwater. (One curie is 37 billion radiation particles per second - a dangerously high exposure). Thus, it remains an important, if not the most important program at the Test Site to fully characterize and to endeavor to clean-up the contamination.

The surface contamination should be clearly illustrated. 

As the primary public document on the NTS, the SWEIS should give the public a clear picture of the level of contamination and its distribution about the NTS. The general public does not have the luxury of time to review the numerous citations within the SWEIS to track down where the contamination is. Thus, DOE must provide clear maps to show areas of contamination and the nature of that contamination. For those sites where characterization is incomplete there should be a marker to show that, so that the public knows what has yet to be done. These maps and associated text should allow a layperson to understand where is the contamination, how much, and what has yet to be analyzed. Section 4 of the SWEIS should be revised to include this information. 

The SWEIS should evaluate an alternative of restoring “clean” lands to public use. 

It is unclear from the SWEIS whether all of the withdrawn land is still needed for the existing missions of the NTS, and whether those missions are still important to the public. However, in order to make this assessment, information is needed regarding the contamination and if any areas are clean and suitable for public use. For example, according to the SWEIS there are about 100 radioactive soils sites and that roughly one-fifth have been “closed.” Section 4 of the SWEIS does not show where the 100 sites are and which have been closed. There is some discussion of the contamination of some locations, but the picture is incomplete. It is also not explained what closed means – what is the level of clean-up at a closed site? The SWEIS should explain the nature of the soils analysis. Are samples drawn from various depths per sampling location and, if so, which elements are part of the analysis? There is mention of gamma ray monitoring; which radioactive elements does this detect? 

Groundwater contamination must be fully understood, defined and disclosed. 

The situation with groundwater contamination at NTS from the underground testing is similar to the soils analysis, but probably less understood. DOE has information on the initial “source term” (how much of each chemical, radioactive or not) created for a few underground explosions. This data is used to estimate the total “source term,” i.e. all the underground tests, which is how the estimated 130 million curies was determined. The SWEIS does not give any data on the source term, or break down the 130 million curies into the various radioactive elements that are estimated to still exist in the groundwater. 

DOE needs to evaluate the potential spread of radioactivity from the underground explosions. 

It is unclear from the SWEIS if the DOE knows how much the contamination from the underground (and below the water table) explosions has spread. Source term data is obtained by drilling a test well near to where the underground explosion was done, so this only gives information at that location. There is a map showing the locations of the underground tests and the five “Corrective Action Units,” which are groupings of these tests, so the locations of initial contamination are known. However, the SWEIS does not show to what extent the radioactive elements from these tests may have spread – being carried by groundwater movement. Tritium (radioactive hydrogen, and the fasting moving contaminant) is the only radioactive element that has been measured moving from these tests near the boundary of the NTS (north western). But what of other contaminants?

Groundwater sampling information must be clearly illustrated. 

There are a number of underground sampling wells around the NTS, which are listed in the SWEIS, and appear to be routinely tested for tritium (radioactive hydrogen) and gross alpha and beta radiation, but there is no map to show where the samples are taken. Again, good visuals are needed here so the public can clearly see where the data is taken and from which aquifer. Then, DOE can give water analysis data for the wells (perhaps in an appendix), which the public can connect to the physical location, to understand the extent of contamination based on the well system. In addition, the Underground Testing Area Project (UGTA) program discussed in the SWEIS has not produced a contamination mapping of the groundwater (like a topographical map, but with radioactive contaminants). 

DOE should verify its assumption that tritium is the only radioactive element of concern from the underground testing. 

Other than tritium, DOE appears not to have any knowledge of other contaminants from the underground tests moving in the groundwater. In fact, it is the opinion of the DOE that only tritium has significantly migrated away from the underground test locations. Thus, DOE appears to have no intension, and to our knowledge has not attempted, to test this assumption on a single underground nuclear explosion shot. Any good scientific analysis would require an experiment to confirm or refute existing theory, and this should be part of the UGTA program. 

Overall, the SWEIS should supply as complete a picture of the existing contamination in a form that is understandable.

 In general there needs to be more information in the SWEIS, even if in summary form, about the extent of contamination at NTS and off-site locations, areas of uncertainty or unknown, what actions are necessary to clean-up know contamination, and the cost for characterization and clean-up. Maps that show sampling locations and calculated results of contamination in map form should be presented. It is vital that the public has a digestible assessment of the contamination, and actions to remedy, if possible, such contamination.

The Expanded Operations Alternative should include increased programs for Environmental Restoration. 

 The NTS/NNSS region is prone to flash flooding and wild- fire that can carry contamination off-site. The SWEIS did not, but should have addressed the issue of wildfire. In the Expanded Operations Alternative there are no proposals for new or expanded Environmental Restoration activities. Additional cleanup and environmental restoration would decrease the danger of surface contamination being carried off-site in smoke from fires. 

ENVIRONMENTAL MANAGEMENT MISSION –
WASTE TRANSPORTATION & STORAGE 

These issues are linked because cleanup involves collecting contaminated soils, equipment, etc., safely containing it, and placing it in a storage facility. The low-level waste sites at the Test Site contain much waste that has been collected and contained from the site itself. Cleanup and restoration activities at the Test Site should continue and be expanded so as to contain and isolate radiation contamination on the site and reduce the possibility of releases from the site to air and water. 

However, the majority of waste stored or disposed there is from other DOE weapons complex sites nationwide. The SWEIS mentions over 20,000 truckloads in recent years. In the interest of avoiding Las Vegas, these shipments have major impacts on the small rural roads leading to the Test Site. Estimates of future waste disposal, based on 1997-2010 current levels (for both Test Site and transported waste from other DOE nuclear weapons sites), is 15 million cubic feet of Low-Level Waste and 900,000 cubic feet of Mixed Low-Level Waste. 

Test Site low-level waste sites should accept wastes from cleanup activities, rather than being available to take waste generated by new waste-producing projects. The Expanded Operations Alternative proposes new projects that will create more waste, and also increases the current waste production from on-going projects. The Test Site should not be seen as an unlimited waste dumping area that encourages future waste production. 

NON-DEFENSE MISSION –
ENERGY USE, ALTERNATIVE ENERGY RESEARCH AND FACILITIES 


Energy Conservation 

Research projects as well as installations of systems that conserve energy will have long-term economic, employment, and academic value. Each alternative has some level of this activity that will have benefits to the Test Site, the Western U.S., and the world. The Expanded Operations Alternative is preferred. 

Renewable Energy Research & On-Site Renewable Energy Projects 

The recommendation of using Test Site lands for small-scale energy research projects not possible elsewhere seems like a good idea. Increased demonstration projects will provide electricity that can be utilized without extending transmission lines. Research and development programs for solar power that minimize water usage are especially important to the Western U.S. These on-site development projects can also help increase development of new de-centralized power sources that reduce the need for transmission lines elsewhere. Geothermal energy production is a source of major water pollution as well as degradation of Native sacred sites. Solar and wind energy are far more appropriate for development in Nevada. We oppose geothermal development. 

Commercial Solar Energy Development 

While we support renewable energy development, large scale facilities with major transmission lines are not generally the best approach. Solar panels should be installed on NTS/NNSS rooftops, over parking areas, and previously disturbed ground surfaces wherever possible. Future ground disturbance at NTS/NNSS must be minimized because some areas have below-surface contamination that would be exposed. Additionally, Native Americans oppose any further ground disturbance on these desert lands treaty lands. These issues will be addressed in Solar Project-specific EIS documents in the future.