NEWS RELEASE - Utah Democratic Party Chair Releases Letter To NNSA
Tuesday, January 9, 2007
Utah State Democratic Party
455 South 300
East Suite 301 | Salt Lake City, UT 84111 |
801-328-1212
News
Release
Contact: Wayne
Holland
801-916-1879 - cell
For
Immediate Release
January 09
2006
Utah Democratic Party Chair
Releases Letter To NNSA
SALT LAKE CITY,
UT – Utah Democratic Party Chairman, Wayne
Holland,
Jr. sent a letter to the National
Nuclear Security Administration
today
outlining his problems with the planned "Divine
Strake" bomb
test, and the Utah Democratic
Party's opposition to it.
Statement from
Wayne Holland, Jr.:
"I am very irritated that the NNSA and
DTRA have decided not to
include public
input in their presentations on the Divine
Strake test.
Too many Utahns, and too many
American families, have been
negatively
impacted from the effects of
being downwind from that test
range.
"The
NNSA and the DTRA have categorically failed to
meet any
expectation of interaction with the
people of Utah and Nevada, and
they are now
further threatening the delicate balance of the
people's
confidence in
Government.
"From denying the people of Utah and
Nevada the chance to have their
voices and
opinions heard, to the last minute change of
venue for the
Salt Lake presentation, the
NNSA and DTRA have shown a pattern
of
behavior that feeds directly into the
people's mistrust and suspicion
for this
entire debacle."
###
January
9, 2007
NNSA/NSO
Divine Strake EA Comments
PO Box 98518
Las
Vegas, NV
89193-8518
To Whom
It May Concern:
The Utah State Democratic Committee
(hereafter referred to as the USDC or Utah
Democratic Party) appreciates this opportunity
to comment on the Draft 2006 Revised
Environmental Assessment for the Large-Scale,
Open-Air Explosive Detonation Divine Strake at
the Nevada Test Site (hereafter Divine Strake
Draft EA). We ask our comments be
incorporated into the public record and that
the USDC be added to your mailing list to
receive all additional documents released for
public comment or review regarding Divine
Strake.
The USDC has several concerns with
regard to the proposed action as outlined
within the Divine Strake Draft EA and the
unwillingness of the National Nuclear Security
Administration (NNSA) to fully include the
public, particularly those living downwind from
the Nevada Test Site (NTS) in the
process. We echo the concerns of
Democratic Congressman Jim Matheson and Utah
Governor Jon Huntsman with regard to the
failure of the NNSA to take public comment at
any of the three open houses scheduled on this
subject.
The USDC urges the NNSA to reconsider
its decision to hold open house style meetings
and hold public hearings that will enable the
people of Utah and Nevada to share their
concerns with your agency. The National
Environmental Policy Act (NEPA) requires
government agencies to “involve environmental
agencies, applicants, and the public, to the
extent practicable, in preparing assessments
required by § 1508.9(a)(1).” (40 CFR
§1501.4). Given the NNSA is planning to
hold open houses in three locations in Utah and
Nevada anyway, it cannot reasonably be argued
it is impractical for the NNSA to allow public
comment at that time.
During the era of both above ground and
underground nuclear testing, it was the policy
of the federal government that prevailing winds
should always be blowing toward Utah prior to
any test. Based on the information
provided within the Draft EA’s description of
the proposed operating plan for Divine Strake,
nothing has changed. The Draft EA states
“required meteorological conditions for
detonation” include “winds less than 25 miles
per hour blowing from the southwest (240
degrees) through southeast (120 degrees).”
(Draft EA, page 2-11). This takes fall
out from the explosion over south, southeast or
east central Nevada and on into southwestern or
west central Utah.
Utahns and citizens throughout the
Western states have long rejected federal
government intrusion without first providing an
opportunity for public involvement in the
decisions impacting their communities. In
1996 the designation of the Grand
Staircase-Escalante National Monument was
designated without the benefit of public
involvement prior to the decision. That
said, at least the actual and potential
environmental consequences of that decision
were benign. In this case, the Bush
administration is taking for granted continued
strong support for the Republican Party
regardless of potential consequences to the
health and well being of Utahns through a
reckless interpretation of public comment
requirements within NEPA and a shoddy
environmental analysis. The current
administration’s lack of regard for the
concerns of Utahns and other westerners living
downwind should be seen as a red flag to all
Utah voters and westerners in
general.
While both the Grand Staircase-Escalante
National Monument designation, Divine Strake,
and recent consideration of renewed nuclear
testing in Nevada all provide obvious examples
of why a political environment in Utah that
does not allow one party to write off the state
and another to take it for granted is not in
our state’s interest, the apparent
unwillingness on the NNSA’s part to provide a
reasonable opportunity for Utahns to express
their concerns through a sincere public hearing
process is an especially cynical and
transparent attempt to take advantage of Utah’s
current loyalty to one party.
The NNSA further demonstrates its
contempt for the public in this case by
proposing only two alternatives, the “No Action
Alternative” required by NEPA and the proposed
action. The Divine Strake Draft EA
completely dismisses a range of intermediate
options from review, including the use of fewer
explosives. The use of “technological
variations and experiment parameters” is
dismissed without even mentioning the possible
use of computer modeling which has been
increasingly relied upon by the NNSA since the
underground nuclear testing moratorium put in
place by President H.W. Bush in 1992.
The NEPA requires all federal agencies
to “Study, develop, and describe appropriate
alternatives to recommended courses of
action in any proposal which involves
unresolved conflicts concerning alternative
uses of available resources as provided by
section 102(2)(E) of the Act.” (40 CFR, §
1501.2(c)) The regulation’s use of the word
“alternatives” as opposed to “alternative”
clearly signals Congress’ intent all viable
alternatives be duly analyzed and the choice of
actions not be limited simply to what an agency
wants to do vs. doing nothing. In this
case the NNSA analyzed only one action
alternative and failed completely to mention
computer modeling or why it would be an
insufficient substitute for the proposed action
in dismissing “technological variations” which
may have provided the data sought by the
agency.
The NEPA and associated implementing
regulations require an agency to describe the
“purpose and need” for any proposed action
subject to NEPA review. While the Divine
Strake Draft EA does describe the purpose and
need for the action, the proposed action
(Divine Strake open-air detonation) does not
meet the stated purpose and need. The
intent of the Divine Strake proposal, as
described within the Draft EA, is to assist
with the development of weapons that can
effectively damage or destroy hardened deeply
buried targets or HDBTs, “including both
tactical and strategic adversarial targets.”
(Page 1-7, Divine Strake Draft EA).
Unfortunately, the inability of
conventional weapons to reach such targets is
well documented. In an article published
in the November 2003 issue of Physic
Today , Robert W. Nelson reports the
Department of Defense already has at its
disposal “tens of thousands of conventional
earth-penetrating weapons capable of destroying
hardened targets like an underground bunker
buried within 10 meters of the surface.”
Unfortunately, when you get much deeper than
that the laws of physics begin to interfere
with the ability of any non-nuclear device to
destroy the target.
According to Nelson’s article, “taking
into account realistic materials strengths,
10-20 m is a rough ceiling on how deeply into
dry rock a warhead can penetrate and still
maintain its integrity.” In short, there
is no “need” to detonate 700 some odd tons of
explosives beneath radioactive earth at the NTS
to determine whether a truly hardened and
deeply buried target can be destroyed by either
conventional or nuclear means. It cannot,
at least not without significant radioactive
fallout and collateral damage. The NNSA
need not waste taxpayer money on such an
experiment, especially given potential
consequences for those Americans living
downwind, to determine the absence of
feasibility in this case.
Finally, the Divine Strake Draft EA makes clear significant levels of radioactive contamination do in fact exist within the near vicinity of the proposed Divine Strake detonation site. Soil sample number DSA07 revealed Plutonium 239 was detectable at a level of 11.1 picocuries per gram and sample number DSA20 was estimated at 4.5 picocuries of Plutonium 239 per gram. At least three additional samples came in at above 2.38 picocuries per gram of soil. (Draft EA, Site Characterization Report, table 3.1.2) According to at least one report published to describe radioactive contamination and cleanup at the Brookhaven National Laboratory “the most protective estimates for exposure, has established that plutonium levels in the environment above 2.44 picocuries per gram could require further analysis.”
(www.bnl.gov/erd/Peconic?Docs
Given these high levels of a man-made
radioactive isotopes, well above the EPA
standard in at least two samples, the USDC has
little confidence airborne radioactive
particles will not be spread at levels
significantly above those considered safe to
either the workers at the NTS or people living
downwind.
The USDC calls upon the NNSA to adopt
the no action alternative in this case due to
the failure to provide the public with all
“practicable” means of providing input, the
failure to meet the stated “purpose and need”
as described within the Divine Strake Draft EA,
and the failure to adequately explore all
reasonable alternatives to the proposed
action. In addition, we believe the
presence of at least two soil samples within
the project area with elevated levels of
plutonium above what the EPA considers safe
render conclusions regarding the safety of both
workers and downwind residents questionable at
best.
The USDC looks forward to your response
to our concerns regarding the Draft Divine
Strake EA. Thank you again for this
opportunity to
comment.
Sincerely,
Wayne Holland
Chair, Utah State Democratic Committee
455 South 300 East, Ste 301
Salt Lake City, UT 84111
(801)328-1212