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October 30, 2002
NEWS RELEASE
FOR IMMEDIATE RELEASE
Contact:
Steve
Erickson 801-554-9029
CITIZENS EDUCATION PROJECT
May 5, 2004
Mr. William Suiter
NEPA Document Manager
National Nuclear Security Administration
P.O. Box 98518
Las Vegas, NV 89193
Dear Sir:
The Citizens Education Project, a Salt Lake City-based nonprofit organization dedicated to informing the public on issues of social and economic justice, submits the following comments on the Preapproval Draft Environmental Assessment for Activities Using Biological Simulants and Releases of Chemicals at the Nevada Test Site.
We have a number of concerns about the programs and activities proposed in this EA, which collectively argues for preparation of a full EIS for what is certainly a major federal action with significant potential impacts.
First, we question the assertion that this expansion of Nevada Test Site-based programs is vital to the NNSA. The EA contains no documentation of the need to test with biological agent simulants and chemicals at NTS, merely a statement that such testing is needed. There is no documented increase in demand from agencies or contractors for access to NTS locations and facilities under the Work for Others program to be found in the EA.
Operational testing has been done extensively in the past, both inside secure laboratories and in the open air at other locations, and such testing continues today. It appears to us that this program would duplicate missions carried out at other government installations such as the U.S. Army Dugway Proving Ground, which have a greater institutional capacity and infrastructure to conduct such testing. Since the EA proposes that only two new employees would be needed to accommodate the testing proposed, the capacity of NTS to implement operational testing with these agents would seem not to be greatly enhanced, at least in the short term. Without further analysis and explanation of the need for additional testing and additional capacity at NTS to perform this testing, this proposal raises the question of whether it is primarily a matter of mission creep”.
We question why the NNSA failed to consider as a separate alternative testing at other locations. Certainly some, if not all, of the proposed tests could be accommodated at other installations and facilities. To fail to examine those options through a comparative analysis undermines the value and credibility of the EA and leads us to wonder if the decision to proceed with these activities has already been made. A full EIS should examine other options as an alternative to the proposed action.
Insufficient information is provided on the NTS locations to be used for proposed tests. Without greater specificity on test locations, it is impossible to determine localized environmental impacts. This is particularly true for tests involving dispersal of agent or agent simulant from mobile sources like aircraft or ground transports. The EA states that suspended aerosols could move off NTS. Specifying locations of tests, especially test locations near NTS boundaries where the likelihood of off-site contamination is greater, is essential so that impacts could be predicted, mitigated, or eliminated.
The EA also contains insufficient information on the potential impacts to migratory birds.
The EA does not specify what chemicals would be used in any of the proposed tests, making it impossible for a reviewer to speculate on potential impacts. A full EIS should provide a list of chemicals which may be used in future tests.
The cumulative impacts analysis (p. 3-16) does not address potential impacts, conflicts, and incompatibilities involving other programs and missions at NTS. A full EIS should address these impacts.
Lastly, there is very little information provided on the proposed use of non-infectious or killed Influenza A virus. It is important to know how the virus is to be killed, and where it will be killed (e.g. on-site at NTS or at another location).
A full EIS should address these issues before a record of decision is made to proceed with these activities.
Respectfully,
Steve Erickson, director
Citizens Education Project
444 Northmont Way
Salt Lake City, UT 84103
9801) 554-9029
Email: erickson.steve1@comcast.net