Close the Nevada Nuclear Test Site!

Dec 5, 2011

FCNL has called for the shutdown of the nuclear testing facilities at the Nevada National Security Site. Read our statement below.

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December 2, 2011

Re: Draft Site-Wide Environmental Impact Statement for the Continued Operation of the Department of Energy/National Nuclear Security Administration Nevada National Security Site and Off-Site Locations in the State of Nevada

To whom it may concern,

The Friends Committee on National Legislation (FCNL) is commenting on the site-wide environmental impact statement (SWEIS) for the Nevada National Security Site (NNSS).

FCNL is a religious lobby in the public interest based on the values of the Quaker faith. FCNL has tens of thousands of constituents across the United States, including Nevada. One of FCNL’s chief policy concerns is nuclear disarmament and nonproliferation. We are providing comment for the SWEIS on this basis.

FCNL rejects all three alternatives outlined in the SWEIS. All three policy alternatives outlined for the Nevada National Security Site (NNSS) in the SWEIS will “[m]aintain readiness to conduct nuclear tests.” Instead of strictly adhering to any one of the three proposed alternatives, FCNL supports the dismantling of facilities meant for use in testing nuclear weapons at NNSS.

I. Nuclear Stockpile is Reliable Without Explosive Testing

The nuclear bomb testing facilities do not need to be maintained because further tests of the country’s nuclear stockpile are not required to ensure reliability. Current and past administration officials agree that there is no need for further tests. During a speech in June of this year, Rose Gottemoeller, Assistant Secretary of State for Verification, Compliance and Implementation, stated that technological advances ensure reliability without testing:

“Today, through the extensive surveillance methods and computational modeling developed under the Stockpile Stewardship Program over the past 15 years, our nuclear experts understand how these weapons work and the effects of aging better than when explosive nuclear testing was conducted.”¹

Former administrator of the National Nuclear Security Administration (NNSA), Linton Brooks also recently expressed confidence that the nuclear stockpile remains safe and reliable without the need for nuclear testing. In a November 2011 interview, Brooks stated that:

“There is no plausible situation in which current stockpile stewardship and the deep scientific understanding … will not be enough to ensure the safety, security and reliability of our nuclear weapons for the indefinite future.”²

In 2010, the directors of the three U.S. nuclear weapons laboratories also expressed confidence that the nuclear stockpile will remain reliable into the future without explosive testing. The Nuclear Posture Review (NPR) by the Obama administration in 2010 calls for the continuation of the nuclear testing moratorium. Lab directors said that the proposed policies in the NPR “provide the necessary technical flexibility to manage the nuclear stockpile into the future with an acceptable level of risk.”³Furthermore, the NPR reports that since the United States stopped explosive nuclear testing in 1992, U.S. “nuclear warheads have been maintained and certified as safe and reliable through a Stockpile Stewardship Program.”⁴

II. U.S. Policy Excludes Further Testing: Moratorium and CTBT Ratification

The United States has not explosively tested a nuclear weapon since 1992. The most recent NPR also makes clear the administration’s guiding principle that, “[t]he United States will not conduct nuclear testing.”⁵ Furthermore, the NPR sets out the ratification and entry into force of the Comprehensive Test Ban Treaty (CTBT) as an explicit policy goal. President Obama announced plans to seek the ratification of the CTBT in his April 5, 2009 speech in Prague.⁶

Since President Obama’s speech in Prague, administration officials have repeatedly made public statements in support of the CTBT and reaffirmed the administration’s intentions to move toward that goal. Such statements include those made by Assistant Secretary of State for Verification, Compliance and Implementation Rose Gottemoeller in July 2011⁷ and by Under Secretary of State for Arms Control and International Security Ellen Tauscher in September 2011.⁸ It is uncertain when the CTBT will be brought before the Senate for ratification. However, it is clear that the current administration does not intend to conduct another nuclear test but will continue the moratorium established in 1992.

Many administration officials and experts agree that nuclear testing is not necessary, and it is clear that the administration does not intend to conduct nuclear tests. If there are not going to be future tests of nuclear weapons, it makes little sense to continue to operate a nuclear testing facility.

III. Wasted Resources

Maintaining NNSS for resumption of nuclear testing is a waste of federal resources at a time of flat budgets. Test site readiness does not have a separate line item in the NNSA budget request for FY 2012, but instead is included in the larger “Readiness in Technical Base and Facilities” account at NNSS. That request was $119.6 million for FY 2012.⁹ The funds being used to prepare for the resumption of nuclear testing should be used for the more urgent nuclear nonproliferation goals at NNSA.

III. History of Success in Dismantlement of Nuclear Test Sites

Two other countries have successfully dismantled nuclear test sites. Kazakhstan closed the former Soviet nuclear testing site at Semipalatinsk in 1991.¹⁰ France also completed the dismantling of its nuclear testing facility on the atolls of Muroroa and Fangataufa in the South Pacific in 1998.¹¹ Both Kazakhstan and France are now considered leaders in the field of nuclear nonproliferation, and are strong participants in the Comprehensive Test Ban Treaty Organization (CTBTO).

IV. Former Nuclear Testing Site Usage Possible

NNSA should not maintain the readiness of the Nevada Nuclear Security Site for explosive nuclear testing. This does not mean that the site needs to be abandoned. The SWEIS proposes many uses for the Nevada Site not involving nuclear tests. NNSA should also should work with the CTBTO to use the former nuclear test site for nuclear test verification simulations. Kazakhstan has led the way in this field by working with the CTBTO on four occasions to use the Semipalatinsk site for this purpose.¹² By conducting such simulations at the nuclear test site, the United States could help strengthen the nuclear test verification abilities of the international community. In turn, the administration’s argument for ratification of the CTBT would be bolstered. By failing to follow Kazakhstan’s example by dismantling the nuclear test site and working with the CTBTO, the United States sacrifices an opportunity to be a leader on nuclear nonproliferation.

Conclusion

The Nevada National Security Site SWEIS should include an alternative under which readiness to conduct nuclear tests is not maintained. The United States has not tested a nuclear weapon in nearly 20 years. It is evident that the current administration does not intend to change that. In fact, the administration is moving toward further barriers to nuclear testing by pushing for the ratification of the CTBT. Experts in the field, from State Department officials to the directors of the three national nuclear labs, have expressed confidence that further testing is not necessary to ensure the safety and reliability of the nuclear stockpile. There is no sense in maintaining a site for nuclear testing when there are no plans to test again. Resources are wasted on maintaining the nuclear testing facilities at the NNSS. The examples that France and Kazakhstan have set by dismantling their nuclear tests sites should be followed by the United States. There are other uses for the site that would position the United States as a leader on nuclear nonproliferation.

Thank you for your consideration.

Sincerely,

David Culp
Legislative Representative

¹Rose Gottemoeller, “Leadership and the Future of Nuclear Energy,” University of Chicago, Chicago, June 9, 2011, http://www.state.gov/t/avc/rls/165433.htm.

²Diana Barnes, “Further U.S. Nuclear Tests Highly Unlikely: Former NNSA Chief,” Global Security Newswire, November 29, 2011, http://www.globalsecuritynewswire.org/gsn/nw_20111129_2394.php.

³Sandia National Laboratories. “Tri-Lab Directors’ Statement on the Nuclear Posture Review,” April 9, 2010, https://share.sandia.gov/news/resources/news_releases/tri-lab-directors%E2%80%99-statement-on-the-nuclear-posture-review/.

⁴U.S. Department of Defense, Nuclear Posture Review Report, April, 2010, http://www.defense.gov/npr/docs/2010%20Nuclear%20Posture%20Review%20Report.pdf.

⁵U.S. Department of Defense, Nuclear Posture Review Report.

⁶Barack Obama, “Remarks by President Barack Obama,” Prague, April 5, 2009, http://www.whitehouse.gov/the_press_office/Remarks-By-President-Barack-Obama-In-Prague-As-Delivered/.

⁷Rose Gottemoeller, “The Status Quo is Unacceptable,” United Nations, New York, July 27, 2011, http://geneva.usmission.gov/2011/07/28/rose-gottemoeller-the-status-quo-is-unacceptable/.

⁸Ellen Tauscher, “The New START Treaty and the CTBT: Two Essential Steps Toward Fulfilling the Prague Agenda,” Women’s Action for New Directions, Washington, September 19, 2011, http://www.state.gov/t/us/173967.htm.

⁹U.S. Department of Energy, FY 2012 Congressional Budget Request. February 2011.

¹⁰Togzhan Kassenova, “Semipalatinsk: From Nuclear Testing to Test Ban Treaty Support,” Carnegie Endowment for International Peace, August 29, 2011, http://carnegieendowment.org/2011/08/29/semipalatinsk-from-nuclear-testing-site-to-test-ban-treaty-support/4x6s.

¹¹“Fifteenth Anniversary of France’s Last Nuclear Test,” CTBTO Preparatory Commission, Vienna, January 27, 2011, http://www.ctbto.org/press-centre/highlights/2011/fifteenth-anniversaryof-frances-last-nuclear-test/.

¹²Togzhan Kassenova, “Semipalatinsk: From Nuclear Testing to Test Ban Treaty Support.”