[NukeNet] Comments on draft eis for Complex transformation, deadline April 10, 2008

Tue Apr 8 17:03:05 EDT 2008

Dear Mr. Wyka,

I appeared at the SRS hearing in North Augusta, SC at your first meeting on complex transformation. We, the public, call it Bombplex. You invited everyone to submit additional statements by April 10,2008, and gave an overview of Complex Transformation. Please add these comments to my original presentation and incorporate this message in your Final Environmental Impact Statement. 

 The most important thing I learned from your presentation is that there are already 10,000 pits stored at Pantex, and 20 additional pits per year are currently being produced at Los Alamos. Each of these pits can be readily transformed into a new nuclear bomb.   It is general knowledge that the U.S. has 6,000 nuclear bombs on hair trigger alert, and another 4,640 ready to be taken out of storage. That makes an effective potential for 20,000 nuclear bombs, on the shelf, now. Why build more?

 At the Savannah River Site (SRS) and Hanford, we have millions of gallons of waste left over from reprocessing the radiated nuclear fuel to extract the plutonium for all these bombs plus those that have been dismantled by the U.S., until our focus shifted from building down to again building up these weapons of mass destruction.   Since 1990, the U.S. has paid over $1 billion per year to Westinghouse in an effort to clean up these 51 tanks of highly radioactive nuclear waste at SRS.  After 18 years, and more than $18 billion, only 2 tanks have been emptied enough to allow them to be grouted.  Dr. Frank Parker, Vanderbilt University, chaired the National Academy of Sciences study that advised DOE to wait until the technology is developed to more fully empty these carbon steel tanks, each larger that the Georgia Capitol dome,  before grouting.  The most radioactive crud encrusted to the bottom of those tanks  cannot be removed.  "Clean Up" is a mirage.  After more than 60 years, there is still no technology capable of cleaning  up nuclear waste.  Each attempt increases the volume.   

In the early 1970's, Representative Leo Ryan issued a congressional report on nuclear power cost.   That study disclosed that up until that time, there had already been over 5,000 studies on what to do with nuclear waste.  Ryan said that the Atomic Energy Commission, predecessor of DOE and NRC, could not even tell his committee how much all those studies had cost.  His conclusion, there were no answers.  That conclusion still holds.  It's now 2008.  How many more studies have been done since Ryan's report?  Now, instead of  developing the technology recommended by NAS's study,  DOE's answer is to ask for more money to build a new Bombplex and more nuclear bombs.  These nuclear bombs and their byproducts, are all waste - waste of money, resources, and talent that should be used for the benefit of mankind, not to build more weapons of mass destruction that threaten all life on earth. 

When the idea of a Modern Pit Facility was first mentioned, the predecessor to Complex 2030 and now Complex Transformation,  the public was told that the plutonium pits were deteriorating.  A recent study has emerged that puts the effective life of these pits at over 100 years.  So, there is no rational reason for building more.  This is more than national pork barrel projects.  We need to rebuild our bridges, literally and figuratively.  The GAO has recently put a price tag of $150 billion on complex transformation.  If it were free, it would be too expensive.   

As I testified at that first public meeting on Complex Transformation, I believe that building Bombplex and new nuclear bombs, (DOE calls them Reliable Replacement Warheads, RRW's) the United States is in violation of the Non-Proliferation Treaty. Even the proposal to build this complex, with its purpose to build  new nuclear weapons, threatens our country. How can any logical person not conclude that this is a treat to our national security?  Are other countries going to sit idly by while we proceed to rebuild our nuclear arsenal? I truly believe that the hidden purpose is to promote the nuclear industry worldwide.  (Global Nuclear Energy Partnership, GNEP.)Increasing the American nuclear arsenal is a trigger for other nations to demand the right to also own nuclear bombs.  To get the raw materials, plutonium and tritium, they need nuclear reactors.  Instead of discouraging nuclear's spread, we are actively promoting it.  

Tying Complex transformation to  GNEP explains the only rational explanation for both.  Every thinking person questions why Arab nations need nuclear power, if not for obtaining material for nuclear weapons.  Nuclear power and nuclear weapons are inseparable.  So, one must ask the question, who stands to benefit from complex transformation?  Follow the dollar.  Nuclear Energy Research Advisory Committee, (NERAC) wrote the blue print for the revival of the nuclear industry, which included the Global Nuclear Initiative, that evolved into GNEP.  It is not hard to conclude that our building more bombs will create a bigger demand for nuclear power plants worldwide. We can therefore answer the questions,  "Who reaps the benefits of complex transformation, and who pays the price."   Enviromental Impact Statements demand a cost benefit analysis.  Please answer that question instead of focusing only on the monitary cost.     
 As I asked at the public meeting, how many nuclear weapons does it take to constitute a deterrent?  Any above that number is pure waste, and worse than the waste of money, is the political tragedy that it poses.  How can we expect other nations to build down, when we continue to build up?  

Your name for the  new  nuclear bomb factories, capable of building an additional 125 pits per year, is "Centers of Excellence," a misnomer, an oxymoron.  The very naming of them is evidence of NNSA's deception. The public's name for this project is more honest and descriptive, "Bombplex." 

In your Environmental Impact Statement (EIS), you must consider the consequences of this action.  All out nuclear war is a potential consequence.  How can you calculate the cost of the end of all life on earth?  The obvious answer is that this is too high a price to pay, and all of your options must be rejected, and compliance with the Non-Proliferation Treaty must be adhered to.

The following is an article I found this morning.  It is attributed to its authors.   I wish to endorse it and ask that you include it as part of my official statement as the preferred alternative.  Promote adherence to the nuclear non proliferation treaty.  Seek peace instead of nuclear war.  Cancel all plans to build any additional nuclear weapons or the facilities to build them. 

Possibilities for a Nuclear-Free World By Lawrence S. Wittner and Jayantha Dhanapala 
IntroductionIn the following opinion piece, which appeared in the March 20, 2008 issue of the Asahi Shimbun, Jayantha Dhanapala—the distinguished former Under-Secretary-General for Disarmament Affairs at the United Nations—not only makes the case for a nuclear-free world, but argues that it is a viable possibility.In Dhanapala's view, the campaign to abolish nuclear weapons has acquired significant momentum thanks to the initiative of four former senior U.S. government officials: George Shultz (Ronald Reagan's secretary of state), Henry Kissinger (Richard Nixon's secretary of state), William Perry (Bill Clinton's secretary of defense), and Sam Nunn (former chair of the senate armed services committee). In January 2007 and, again, in January 2008, they published powerful opinion pieces in the Wall Street Journal that outlined the need for a nuclear-free world, as well as steps in that direction. Since that time, Dhanapala notes, there has been important follow-up to this initiative by other former national security officials and nuclear experts.As none of these former U.S. government officials showed much interest in the idea of abolishing nuclear weapons in the past, how should we account for their newfound zeal? Part of the answer seems to lie in their fear that terrorists will acquire and use nuclear weapons. As they stated in the first paragraph of their 2008 article: "We face a very real possibility that the deadliest weapons ever invented could fall into dangerous hands." Of course, many people believe (and have believed for decades) that nuclear weapons are already in "dangerous hands." Nevertheless, it is hard not to agree that adding terrorist bands—or additional nations--to the list of the nuclear-armed will raise the level of nuclear danger.A second factor that might explain why portions of the U.S. national security elite are keener on nuclear abolition than in the past is that U.S. conventional military power is far superior to that of any other nation. In reality, as U.S. scientists began warning in 1945, U.S. national security can be maintained better in a non-nuclear world than in a world bristling with nuclear weapons. Even so, people of good will might still welcome the Shultz-Kissinger-Perry-Nunn initiative for, although it appears to contain an element of self-interest and to return us to the pre-nuclear era debate over the broader issue of using military force to maintain national security, it does enhance the prospects for human survival.A more telling objection to this focus on a group of former national security managers is that they might not be sufficient for the task at hand. For one thing, there are plenty of national security officials who are not at all interested in nuclear abolition—or at least nuclear abolition for their country! And these people are in power. As Dhanapala observes, at present "there are no ongoing negotiations for nuclear weapons reductions." Conversely, there is plenty of pro-nuclear activity by government officials. Although the Bush administration has focused on nuclear projects in Iran and North Korea, it has consistently supported the building of new nuclear weapons by the United States. Moreover, it has winked at the development of nuclear weapons by India and Pakistan. Indeed, it recently pushed through Congress a nuclear technology sharing agreement with the Indian government that will upgrade the ability of that government to churn out nuclear weapons.The leaders of many non-nuclear nations, of course, are less enthusiastic about the ongoing nuclear arms race. Even so, there has been an erosion of their willingness to challenge the policies of nuclear-armed nations. The emergence of the nonaligned movement during the 1950s provided powerful international pressure upon the great powers for an end to the testing, development, and deployment of nuclear weapons. For decades, Third World nations played a key role in the nonaligned movement, and were particularly sharp in their condemnation of the Soviet-American nuclear confrontation. Today, however, relatively little antinuclear rhetoric seems to emanate from these nations. Furthermore, although there was substantial nuclear disarmament in the past, that progress toward a nuclear-free world was based heavily on massive popular pressure from peace and disarmament organizations. In the United States, groups like the National Committee for a Sane Nuclear Policy (SANE), Women Strike for Peace, the Nuclear Weapons Freeze Campaign, and Physicians for Social Responsibility helped create a national uproar over the nuclear arms race. They were joined in their protest ventures by the Campaign for Nuclear Disarmament in Britain, the Congress Against Atomic and Hydrogen Bombs (Gensuikin) and the Council Against Atomic and Hydrogen Bombs (Gensuikyo) in Japan, Project Ploughshares in Canada, the Trust Groups in the Soviet Union, and hundreds of similar organizations around the world. This activist pressure, plus the antinuclear sentiments of the general public, led politicians in numerous nations to abandon many of their nuclear ambitions. But, although polls show that popular sentiment remains antinuclear, that previous massive campaign against nuclear weapons is largely absent today.Thus, ironically, when portions of the national security elite have finally come around to championing a nuclear-free world, much of the popular antinuclear movement is dormant. Can it be revived? Perhaps so. Groups like Peace Action (the successor to SANE and the Freeze), Physicians for Social Responsibility, the Nuclear Age Peace Foundation, and Faithful Security are among those striving to spark a resurrection of the nuclear disarmament campaign in the United States. And others are at work abroad. But popular protest against nuclear weapons remains far from its peak in the mid-1980s.At present, then, Dhanapala—and all other people committed to human survival—should certainly welcome the recent antinuclear activities of a portion of the national security elite. But, as he implies, substantial progress toward a nuclear-free world remains dependent on a revival of pressure from non-nuclear nations and from the public.   Lawrence S. WittnerFrom pie in the sky toward a nuke-free worldJayantha DhanapalaThe vision of a nuclear weapon-free world was most famously dismissed by the former Prime Minister of Britain, Margaret Thatcher, as a "pie in the sky." Such was the derision which greeted the disarmament scenario championed by governments, especially from the Non-aligned Movement, as well as nongovernmental organizations such as Pugwash.It is therefore a revolutionary change to see senior officials in former U.S. Administrations combine to write--not one but two--pieces in the conservative Wall Street Journal, calling for such pie in the sky.In the past, other senior members of U.S. Administrations, like Robert McNamara, and retired military top brass, like Gen. Lee Butler, have also experienced epiphanies and recanted their views on nuclear weapons.What distinguishes this year-long initiative by George Shultz, Henry Kissinger, Sam Nunn and William Perry is the fact that they have been able to gather a number of distinguished U.S. individuals like Madeleine Albright, James Baker III, Zbigniew Brzezinski, Warren Christopher and Colin Powell behind them with a group of scholars in Stanford University's Hoover Institution providing the scientific expertise.The influence of this extraordinary initiative is beginning to percolate in the campaigns for the U.S. presidential elections and the policies of other countries like Britain. At the end of February, the Norwegian government hosted a meeting of global experts in Oslo to carry the initiative further.A major aim of the initiative is to make the goal of a nuclear weapons-free world into "a joint enterprise."The need for broader support is obvious. Not only do many of the nuclear weapon states (NWS) and NATO retain policies for the first use of nuclear weapons, but some also have plans for preemptive strikes and the building of new weapons with the specific intent of violating the taboo that has existed since the tragedies of Hiroshima and Nagasaki.The Nuclear Nonproliferation Treaty that has long stood against proliferation and represented a hope for nuclear disarmament is now in grave jeopardy.There are no ongoing negotiations for nuclear weapons reductions; negotiations about the nuclear programs of North Korea and Iran are still inconclusive, and there is growing evidence of terrorist groups seeking access to nuclear weapons technology and materials.Faced with this seemingly entrenched attitude in favor of nuclear weapons and their use, broader support for an initiative that will eventually lead to the elimination of the world's 26,000 nuclear weapons must come primarily from the governments and peoples of the NWS, two of which, the United States and Russia--who own 95 percent of the weapons--will soon have new presidents.At the same time the non-nuclear weapon states (NNWS) and their citizens also have a right, and indeed an obligation, to take steps that will help usher in a nuclear weapons-free world.The NNWS do not, however, form a monolithic group. There are the NNWS who are allied to NWS and who, like Japan, enjoy the benefits of a security umbrella by belonging to a security pact or, like Canada, to a security alliance (NATO) with "nuclear sharing" arrangements.The NATO summits in April 2008 and again on the 60th anniversary of the alliance in 2009 will enable a review of the 1999 Strategic Concept.The involvement of some NNWS in ballistic missile defense plans clearly linked to nuclear weapons strategy is another factor compromising these NNWS.But we do have a unique opportunity where the fulfillment of the reciprocal, albeit asymmetrical, obligations of the nuclear "haves" and "have-nots" can together help to usher in a nuclear weapons-free world. This is the "partnership" the Wall Street Journal articles call for.A new U.S. president can take the lead. But for this United States leadership to be effective, the support for the Shultz/Kissinger/Nunn/Perry initiative must also come from other NWS and the NNWS.Sweden sponsored the Weapons of Mass Destruction Commission (WMDC), chaired by the respected Hans Blix, which proposed a world summit on disarmament, nonproliferation and terrorist use of weapons of mass destruction.The time is right to prepare for this summit in 2009. The alternative is too awful to contemplate.As the Blix Report noted, "So long as any state has such weapons--especially nuclear weapons--others will want them.So long as any such weapons remain in any state's arsenal, there is a high risk they will one day be used, by design or accident. Any such use would be catastrophic."

Lawrence S. Wittner is Professor of History at the State University of New York/Albany and the author of The Struggle Against the Bomb (Stanford University Press). Jayantha Dhanapala is a former ambassador of Sri Lanka to the United States and a former U.N. Under-Secretary-General for Disarmament Affairs. He is currently chair of the U.N. University Council, president of the Pugwash Conferences on Science and World Affairs and Simons Visiting Professor at Simon Fraser University in Vancouver.

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© Nuclear Age Peace Foundation

 2008    www.WagingPeace.org 

Please send me a copy of your final EIS that includes all of the statements that you receive  during the comment period, and your response to this and all others.

Respectfully submitted,

Jeannine Honicker
704 Camellia Drive
LaGrange, Ga. 30240

phone 706-884-7765

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