The public hearings concerning the Complex Transformation plan to build a new nuclear weapons site at Y12 as well as other places ends on April 10th, 2008. If you want to help stop this dreadful plan then send your comments to one of the following:

Regular mail:

Mr. Ted Wyka, NNSA
Office of Transformation NA-10.1
1000 Independence Ave. S.W.
Washington, D.C. 20585

e-mail:

complextransformation-AT-nnsa.doe.gov or
www.complextransformationspeis.com

fax: 1-703-931-9222

Time is short. If you want to help stop this send them your comments NOW. The following was submitted by Ralph Hutchison, coordinator - Oak Ridge Environmental Peace Alliance.

Comments at Public Hearing on the
Draft Supplemental Programmatic Environmental Impact Statement
on the Transformation of the Nuclear Weapons Complex
February 26, 2008
Oak Ridge, Tennessee

First, the Draft SPEIS is deficient in its failure to respond adequately to 33,000 public scoping comments, more than 32,000 of which advocated a weapons complex that produces no bombs. In response, DOE scaled back its wish list to a Capacity-Based" weapons complex which only builds 80 warheads. This is not an adequate response.

This PEIS must fully develop and analyze a No Production Alternative. Given the recent declarations by former national security, arms control, military and diplomatic leaders that the US must take practical steps now to lead the world to complete disarmament, it is reasonable to project a weapons complex that produces no bombs; this programmatic EIS must analyze this option as a serious possibility.

Is it reasonable to imagine a world where the US is fully compliant with its obligations under the Nonproliferation Treaty? If so, we are headed toward a future which contains a weapons complex dedicated to disassembly, dismantlement, safeguarding and disposition. Is it time, now? This question is answered by leaders from around the world who declare it is crucial that we take concrete practical steps now.

The No Production Alternative will end the Stockpile Life Extension program and abandon the pursuit of new nuclear weapons designs; it will dramatically reduce the footprint of the weapons complex, free up significant funds for environmental restoration work, employ a full and vigorous workforce for decades addressing the backlog of weapons awaiting dismantlement and disposition, support US efforts to stop nuclear proliferation, and place us on the right side of the Nonproliferation Treaty.

Second, the Draft SPEIS presumes to evaluate environmental impacts and has several charts comparing the impacts of the alternatives at various weapons sites. These comparisons are fatally flawed, however, in that they seem to assume each site starts out equally. In fact, profound environmental contamination of various kinds at each of these sites is responsible for radical differences in the baseline, if you will, of each of these sites.

Imagine we are each asked to paint a picture of the future with nice watercolors and given a similar set of brushes and paints. But instead of each of us being given a nice clean canvas to paint on, I receive a brown, smeared canvas; you are given a crumpled tin can; he is given an old rubber tire, and she receives a stained piece of paper. How do we compare our paintings when we are finished?

At Y12, for instance, according to this document samples of surface water-surface water, not groundwater-in 2004 showed cadmium, copper, mercury at two locations, and zinc in concentrations exceeding Tennessee Water Quality Criteria (4-356). At one station, 284 mercury samples exceeded the criteria-or 77 percent, if the readings are daily.

In order to adequately compare environmental impacts in making programmatic decisions-the central purpose of this document-DOE must start with the real world, fully characterize and describe each site's starting point, and go from there. Otherwise, the comparisons are meaningless.

Third, the SPEIS may not be used to sit a Uranium Processing Facility at Y12. It may designate Y12 as a preferred location for a Uranium Processing Facility, but until a complete Environmental Impact Statement for Y12-which has been in the works for a year longer than this process and still has not produced a draft-until that EIS is completed, no final decision can be made about siting a UPF at Y12.

I know, Mr. Wyka, that you assured me on the phone that this would not be case, but my experience with past programmatic EISs has told me differently. I don't want to arrive here in eight months to be told, "Whether or not we do it is not on the table, that decision was made in the SPEIS. Any decision made here must be provisional, and I am putting that on the record today.

Finally, for almost twenty years I have been coming to hearings in Oak Ridge to advocate for an end to weapons production, responsible environmental restoration, and protection of worker and public health. Sometimes it seems like we're watching the same movie over and over, only the name of the document changes.

Not today. For today history has come to meet us. Our call for a weapons complex that produces no bombs resonates with the leading authorities on security in this country. We stand at a pivotal moment-even Congress, with its call for a reevaluation of our nuclear policy in order to determine what kind of weapons complex truly meets the security needs of our country, recognizes this.

History meets us here, and history will judge us. History will count who among us took steps to free future generations from the nuclear chokehold under which my generation grew up. We can make history; we can write the future we want for our children and all the world's children. It can be safer, we can be free of at least this monstrous fear-that all creation will disappear in one afternoon. The time is ripe-the SPEIS on Complex Transformation must include this future as a reasonable alternative.

Ralph Hutchison, coordinator
Oak Ridge Environmental Peace Alliance

We have stopped this before.

Information about this Complex Transformation can be found at:
www.stopthebombs.org

Email: ffpindy-AT-hotmail.com