| Planning
    on writing comments to the NNSA about their Divine
    Strake Environmental Assessment?  Here
    is the full-text of our comments written on Jan. 9, 2007 and revised on Feb.
    3, 2007, for
    submission to the NNSA: The draft
    revised environmental assessment for the Divine Strake test released by the
    National Nuclear Security Administration on January 4, 2007, does not allude
    to, nor does it attempt to reconstruct the concentrations of fallout from,
    six above-ground nuclear explosions identified by Richard L. Miller - who
    filed a paper in the lawsuit of Winnemucca Indian Colony, et. al., vs.
    United States of America et. al. - that could have spread contamination
    over the proposed ground-zero of Divine Strake. The Divine
    Strake ground-zero, located within the U16b complex, is located between four
    to eight miles west of where the six atmospheric nuclear tests identified by
    Miller were conducted.  Those tests were conducted between
    1955 and 1957 by the Atomic Energy Commission, which was the predecessor
    organization to the current U.S. Department of Energy.  Although
    the Divine Strake GZ is located west of Yucca Flat (where those 1950s tests
    were conducted), the radioactive plumes from the six texts identified by
    Miller - Smoky, Turk, Shasta, Kepler, Galileo and Coulomb B - uniquely
    traveled in a westward direction.   (A map generated
    by Microsoft Streets & Trips using the coordinates of the six tests and
    the ground-zero of Divine Strake can be found at http://www.stopdivinestrake.com/divine_strake_map.html 
    The data of the coordinates of the six tests are based on data from
    the document titled 'United States Nuclear Tests' DOE/NV-209-REV 15. 
    The Divine Strake GZ coordinate is based on data from the DOE). Information gathered from government
    documents
    about the trajectories of the fallout clouds from the six tests identified
    by Miller is described below: The cloud
    from Coulomb B, which was detonated on September 6, 1957 with a total yield
    of 0.3 kilotons, traveled in a westward direction.  This
    is clearly shown on the close-in radiation contour map generated by the
    Defense Nuclear Agency, the predecessor agency to the Defense Threat
    Reduction Agency.  (Source: DASA 1251 "Local Fallout
    from Nuclear Test Detonations." U.S. Army Nuclear Defense Laboratory,
    Defense Nuclear Agency p. 185.)  Coulomb B was one of
    several 'safety experiments' that involved the deliberate dispersal of
    Plutonium-239.  Shot
    Galileo was detonated on September 2, 1957 with a total yield of 11
    kilotons.  The Atomic Energy Commission's (AEC) press
    release from the date of the detonation described the immediate fallout as
    follows: "The cloud top rose to above 37,000 feet and, because of near
    calm winds at most altitudes it appeared to hover motionless for
    considerable periods...Cloud tracking aircraft reported 40 minutes after the
    detonation that the total cloud was being divided by the winds into two
    major sections. The section above 17,000 feet was moving quite slowly toward
    the southwest, while the section below 17,000 feet was moving even more
    slowly toward the northwest. Both sections were being dispersed by the
    action of winds blowing from widely varying directions. If forecast
    conditions hold, it is probable that both sections will follow clockwise
    curving paths, and that any significant fallout will be on the Test Site and
    adjacent portions of the controlled bombing range." Shot
    Kepler was detonated on July 24, 1957 with a total yield of 10 kilotons.  
    The AEC press release stated: "The main portion of the cloud rose
    rapidly to 27,000 feet with the upper layers being blown slowly to the
    east-northeast and the lower layers being blown west-northwest. The lower
    portion of the cloud formed a "U" shape and is moving slowly
    toward the northwest." Shot Smoky
    was detonated on August 31, 1957, in an area of north Yucca Flat that is
    ringed to the north and west by mesas.  Smoky's total
    yield was 44 kilotons.  "The elevation at ground zero
    was about 1,400 m, and the elevation of the mesas reaches about 2,300 m. The
    detonation occurred about one-half hour before sunrise...However, as the
    sun rose, it is plausible that warming of the east- and south-facing slopes
    of the mesas caused an updraft and, therefore, a northwestly wind at low
    elevations in the area of the maneuvers..." (Source: National Academies
    Press, A Review of the Dose Reconstruction Program of the Defense Threat
    Reduction Agency (2003), page 356). Shot
                                  Turk was detonated on March 7, 1957 with a
                                  total yield of 43 kilotons.  The Dept. of
                                  Defense document DNA6010F titled 'Shots Wasp
                                  to Hornet: The First Five Teapot Tests' states
                                  that at the time of detonation the surface
                                  winds were from the north at 10,000 feet, the
                                  northeast at 20,000 feet, the south-southeast
                                  at 30,000 feet, and from the west at 45,000
                                  feet. "The main portion of the TURK cloud
                                  and subsequent fallout drifted west and
                                  north." (p.102)  Page 125 of the
                                  document states: "Cloud-tracking at Shot
                                  TURK was more complicated than at previous
                                  shots.  Upon detonation at 0520 hours on
                                  7 March 1955, the TURK nuclear cloud separated
                                  into an uneven mass, forcing the three
                                  cloud-trackers to fly different courses...A
                                  B-29 from Kirtland AFB followed another
                                  portion of the cloud northwest at an altitude
                                  of 20,000 to 23,000 feet MSL until it reached
                                  Tonopah, Nevada." Shot
                                  Shasta was detonated on August 18, 1957 with a
                                  total yield of 17 kilotons.  The Dept. of
                                  Defense document DNA 6006F titled 'Shots
                                  Diablo to Franklin Prime: The Mid-Series Tests
                                  of the Plumbbob Series' states that at the
                                  time of detonation the surface winds were from
                                  the southwest at 10,000 feet, the southeast at
                                  20,000 feet, and the west at 30,000 feet. 
                                  "The SHASTA cloud top rose to 32,000 feet
                                  and moved east, while the middle section moved
                                  northwest, and the lower section drifted
                                  northeast from the point of detonation."
                                  (DNA 6006F; pages 121-122)  Conclusion: The draft
    revised environmental assessment for the Divine Strake test fails to take
    into consideration the full extent of fallout from all historic testing at
    the Nevada Test Site.  Information about the fallout
                                  patterns from the 1950's tests identified by
                                  Miller should be highly relevant to and
                                  included in the National Nuclear Security Administration's
                                  environmental assessments (including the
                                  draft REA released on January 4, 2007),
                                  however there is no mention of these six
                                  tests in any of the EAs.  The fallout concentrations from one or
    more of those six tests, if they indeed deposited fallout
    in and around the U16b complex, should render the complex too dangerous
    for any above-ground testing.   The radioactive cloud
                                  from just one of these tests, Shot Coulomb B,
                                  drifted directly over the coordinates of the
                                  proposed Divine Strake GZ and therefore
                                  most likely deposited radionuclides, notably
                                  Plutonium 239 (Pu-239), in such high
                                  quantities that the blast from Divine Strake would pose a significant danger to
                                  public health.   The completion of
                                  an Environmental Impact Statement would be a
                                  waste of taxpayer monies for the singular
                                  reason that ample evidence - such as the
                                  information provided in these comments - that
                                  should have been included in the EA, but was
                                  omitted for whatever reason, would be enough
                                  to convince any legislator or scientist that
                                  conducting Divine Strake at the U16b complex
                                  is a significant danger to public
                                  health.    |