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Centralized Storage

With the scientifically unsound proposed Yucca Mountain radioactive waste dump now canceled, the danger of "interim" storage threatens. This means that radioactive waste could be "temporarily" parked in open air lots, vulnerable to accident and attack, while a new repository site is sought.

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Entries by admin (702)

Friday
Oct302020

SLOMFP comments opposing ISP/WCS CISF in TX

Thursday
Oct292020

HELP STOP TX NUKE DUMP! Written comments due 11/3 

Interim Storage Partners proposes consolidated interim storage for highly radioactive wastes at Waste Control Specialists in Texas, 0.37 miles from the New Mexico state line. Please help resist this environmental injustice, targeting majority Latinx communities already heavily burdened with nuclear and fossil fuel pollution. Written comments are due by Tuesday, November 3 (Election Day). Individuals can submit written comments via Public Citizen, SEED Coalition, and/or NIRS webforms; or email individual comments to WCS_CISF_EIS@nrc.gov, using our written comments to help prepare your own. There is an organizational comment letter; sign on by emailing kevin@beyondnuclear.org your name, title, group name, city, and state. Help stop environmental racism & thousands of Mobile Chernobyls nationwide! Please spread the word!
Tuesday
Oct272020

Beyond Nuclear's 22nd set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: our member and supporter's comment on the fallacy of "interim" storage

Submitted via: <WCS_CISF_EIS@nrc.gov>

Dear NRC Staff,

We submit these comments on behalf of our member and supporter, David Preston, at his request. Please find David's comments, below, in italics.

 The subject matter David has raised has gotten little to no attention in NRC's ISP/WCS CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement.

Please address and rectify your woefully inadequate "hard look" under NEPA, re: this health-, safety-, and environmentally-significant, as well as legally-binding, subject matter.

And please acknowledge your receipt of these comments, and confirm their inclusion as official public comments in the record of this docket.

Thank you.

Sincerely,

Kay Drey, President, Board of Directors, Beyond Nuclear

and

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear

David Preston's comments:

Re: High-Level Storage


“Interim Storage” is an oxymoron and a blatant lie. Once this radioactive detritus is in place, it will never be (re)moved.


If Nevada is fighting permanent storage, temporary storage should be a non-starter.


David Preston
Friday
Oct232020

Beyond Nuclear's 21st set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS, re: Why Are These CISF Risks Being Taken? To Offload High-Level Radioactive Wastes' Title (Ownership) and Liability on the Backs of the Public Taxpayer

Submitted via: <WCS_CISF_EIS@nrc.gov>

Dear NRC Staff,

We submit these comments on behalf of our members and supporters, not only in New Mexico and Texas, near the targeted ISP/WCS CISF site, but across both of these states, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to ISP/WCS's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- wrongly and illegally assumed by ISP/WCS, as well as by NRC, to someday (or some decade, or some century) become a permanent disposal repository. This unnecessarily repeated, multiple legged, cross-continental transport of highly radioactive waste, is another significant aspect of the EJ (Environmental Justice) burden associated with this ISP/WCS CISF scheme.

The following subject matter has gotten little to no attention in NRC's Holtec CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement:

Why Are These CISF Risks Being Taken? To Offload High-Level Radioactive Wastes' Title (Ownership) and Liability on the Backs of the Public Taxpayer

In addition, these comments show that there is no legitimate nor reasonable purpose and need for the ISP/WCS CISF, targeting Andrews County in West Texas, very near Eunice, New Mexico, in the first place. Such title/ownership transfer -- essentially to further the nuclear power industry's greed driven agenda -- is not a good reason to advance CISFs. In fact, as communicated in previous Beyond Nuclear comments, and touched on below, such a title transfer to DOE is prohibited by the Nuclear Waste Policy Act of 1982, as Amended. That law bars title transfer to DOE, for interim storage, unless and until a permanent repository is licensed and operating.

As laid out by my previous comments submitted in this proceeding, there are many significant risks associated with ISP/WCS's proposed CISF. So why are these CISF risks to be taken? For no good reason. Certainly not to increase public health, safety, security, or environmental protection, despite ISP, WCS, nuclear power industry, and NRC claims and PR spin to the contrary. Truth be told, it’s to expedite or accelerate the transfer of title, liability, costs, and risks, for the highly radioactive irradiated nuclear fuel, from the private commercial companies that generated it, and profited from its generation, onto the backs of federal taxpayers. That’s a pretty big favor to the companies – in fact, it’s unique in all of industry! And it happens to be illegal. It is a violation of the Nuclear Waste Policy Act of 1982, as Amended. It violates the grand bargain that was struck between the U.S. government and the nuclear power industry, that interim storage is the industry's responsibility, while permanent disposal is the U.S. federal government's responsibility (that is, federal taxpayers, in the end). Now, the industry wants to accelerate title transfer, even before a repository is open. That is, the industry wants the public to pay for interim storage costs as well, in addition to the very long list of public subsidies the industry has enjoyed, at public expense, for more than half a century.

Dr. Mark Cooper of Vermont Law School calculated, in December 2013, in his expert witness comments to the U.S. Nuclear Regulatory Commission’s (NRC) Nuclear Waste Confidence/Continued Storage of Spent Nuclear Fuel Generic EIS proceeding, calculated that the first 200 years of commercial irradiated nuclear fuel storage will cost a "staggering" $210 to 350 billion (yes, with a B). (See his expert comments at

< https://web.archive.org/web/20160909042541/http://www.nirs.org/radwaste/exhibitd2013-12-16markcooperfinaldeclaration.pdf>, as well as the related press release at

< http://www.cleanenergy.org/2013/12/19/waste-disposal-nrc/>. I have also attached Cooper's testimony to this email.) His estimate assumed two centralized (or consolidated) interim storage sites (or facilities), one permanent disposal geologic repository, and ongoing on-site storage at nuclear power plants, as needed. It effectively doubled the costs of nuclear-generated electricity, in one fell swoop, because these particular irradiated nuclear fuel management costs had conveniently (for the nuclear power industry) previously never been accounted for. Thus, the consolidated interim storage facility, as at ISP/WCS's CISF site in Andrews County, extreme West TX, so very near Eunice, NM, would be yet another significant public subsidy, for the nuclear power industry, on top of more than a half-century of other significant public subsidies of various and numerous sorts. (See the Union of Concerned Scientists’ 2011 report < http://www.ucsusa.org/nuclear-power/cost-nuclear-power/nuclear-power-subsidies-report#.WK3Iz4WkUZU>, for a comprehensive overview of the many assorted, numerous, some of them unique and unmatched by any other industry, public subsidies the nuclear power industry has enjoyed over the past many decades.) It is worth noting that none of this public subsidization of the nuclear power industry is included in the NRC's DEIS, such as in the socio-economic impacts sections, or anywhere else, for that matter.

At NRC public comment meetings in NM and TX in mid-Feb. 2017, re: the Interim Storage Partners CISF, WCS (Waste Control Specialists) CEO Rod Baltzer pushed back against such criticisms. He said that the taxpayer is already obligated to pay for irradiated nuclear fuel storage, because DOE signed contracts with utilities in the 1980s, pledging to begin "taking out the garbage" beginning by Jan. 31, 1998. He pointed out that the utilities have sued DOE for partial breach of contract, and won damages from the U.S. Judgment Fund, which draws taxpayer funding from the U.S. Treasury, not ratepayer funding from the Nuclear Waste Fund.

Baltzer is right on this one point: U.S. taxpayers are hemorrhaging $500 million to $800 million per year in these partial breach of contract damage awards, as Beyond Nuclear reported way back in 2010

< http://ieer.org/wp/wp-content/uploads/2010/03/NewWasteDisposalContractsBackgrounderFINAL3.pdf>.

(Baltzer now works in a leadership position at Deep Isolation, Inc. Holtec CEO Krishna Singh, at his Holtec CISF license application unveiling press conference held on Capitol Hill in Washington, D.C., in early April 2017, said that he regards the ISP CISF, proposed at WCS, TX, just 39 miles from the Holtec CISF site, as complementary, not as a competitor.)

But our criticism actually still holds. Under the Nuclear Waste Policy Act of 1982, as Amended, the nuclear utilities are responsible for interim storage of irradiated nuclear fuel. Taxpayers are responsible, most unfortunately, "only" for final disposal (DOE's most recent estimate -- several years ago now -- for the price tag of the Yucca Mountain dump, if it were to go forward, was nearly $100 billion, for the first 200 years of operations; adjusted for inflation alone, that price tag would now surpass $100 billion; this is yet another massive public subsidy to the already very heavily subsidized nuclear power industry). But obviously now, the nuclear power utilities would like to transfer even consolidated interim storage facility expenses onto the backs of U.S. taxpayers, ASAP, as with DOE taking title and liability for commercial irradiated nuclear fuel bound for, and stored at, CISFs, such as Holtec/ELEA's in NM, and ISP's at WCS, TX.

This simple fact formed the basis for an environmental coalition letter to NRC in Oct. 2016, pointing out that the WCS license application is illegal, and that the agency should cease and desist from processing it. (For additional information, see:

http://archive.beyondnuclear.org/centralized-storage/2016/10/26/despite-setbacks-beyond-nuclear-and-allies-continue-to-chall.html )

Even though that letter focused on ISP/WCS in TX, the same legal principles and arguments also apply at Holtec/ELEA's CISF in NM, as Beyond Nuclear and other groups have raised at every turn over the past four long years, such as during NRC's Holtec and ISP CISF environmental scoping public comment periods, during the NRC ASLB Holtec and ISP CISF licensing proceedings, in letters and legal appeals to the NRC Commissioners in both licensing proceedings, and now during NRC's Holtec and ISP CISF DEIS public comment periods.

Current law requires a final disposal repository to be licensed, open and operating (not just proposed, nor even nearing being granted a license), before a centralized (consolidated) interim storage site (facility) can be opened, that would rely upon the federal DOE to pay all the expenses -- in effect, taking title to, and liability for, commercial irradiated nuclear fuel interim storage. But there is no licensed repository open and operating. There is no prospect for one for another 28 years, if not significantly longer. So this ISP/WCS CISF, and the Holtec/ELEA CISF, proposals violate the Nuclear Waste Policy Act of 1982, as Amended. And because NRC refuses to stop processing illegal license applications, the agency is also violating the Administrative Procedure Act.

Both Holtec and ISP are seeking to do an end run around this legal constraint. This is very risky for the U.S. federal taxpayer. The linkage between an operating final disposal repository, and a centralized interim storage site, in the Nuclear Waste Policy Act of 1982, as Amended, is to guard against consolidated interim storage facilities from becoming de facto permanent, surface storage parking lot dumps -- the costs, liabilities and risks of which, the U.S. federal taxpayer may get stuck with indefinitely, or forevermore (which is how long highly radioactive waste remain hazardous).

This end run around the legally mandated, precautionary linkage between a licensed and open/operating repository, and centralized interim storage facilities, that Holtec and ISP seek, would be a huge boon to the nuclear power industry. It would expedite the transfer of all costs, risks, and liabilities for irradiated nuclear fuel, from the utilities that profited from its generation, onto the backs of U.S. federal taxpayers, sooner rather than later -- even before a repository is licensed, open and operating. Long before, actually: the DOE’s most recent estimate, as to when a repository can be opened, is 2048! And, as laid out in comments we've previously submitted in this proceeding, as well as the Holtec proceeding, even that 2048 date may be overly optimistic.

Such an accelerated transfer of title for, and the costs, risks, and liabilities for, commercial irradiated nuclear fuel, means the nuclear utilities can walk away from the mess they’ve made all the sooner, removing that headache from their own ledgers. This would be yet another lucrative public subsidy for the nuclear power industry, this one paid by the U.S. taxpayer.

Holtec and ISP are clear about those costs, risks, and liabilities. In both Holtec's and ISP's initial license applications, both companies were careful, making it a licensing condition, that all those costs, risks, and liabilities for the commercial irradiated nuclear fuel, would be solely on DOE – that is, on U.S. federal taxpayers. Holtec and ISP would not accept any of those costs, risks, or liabilities. This of course set up a moral hazard with a highly radioactive twist. Holtec and ISP, private, for-profit companies, would have every incentive to cut corners, and take short cuts on safety and environmental protection, in order to save money, and boost their own profits. After all, DOE – U.S. federal taxpayers – would be shouldering all costs, risks, and liabilities. If anything were to go wrong, it would not be Holtec’s nor ISP's problem – it would be the taxpayers’ problem!

Only when Beyond Nuclear, and other groups, challenged this in Holtec's and ISP's NRC ASLB licensing proceedings, and during the NRC environmental scopings for both of these CISFs, did Holtec and ISP change their applications, adding <and/or licensee title holders>, in addition to DOE, as potential customers at the CISFs. Beyond Nuclear, and other groups, such as Don't Waste Michigan et al. (a seven group, national grassroots environmental coalition), and Sierra Club (the oldest, and largest, environmental group in the country), continued to press their point, and raise their legal objection, however, throughout the ASLB licensing proceedings, as well as on appeal to the NRC Commissioners. Now that not only the ASLB, but also the NRC Commissioners, have rejected all such interventions and appeals in the Holtec licensing proceeding, the Holtec CISF opponents have appealed to the federal courts. And when the NRC Commissioners pull the trigger, and reject all CISF opponents' appeals in the ISP licensing proceeding, then our groups and coalitions (including Beyond Nuclear) stand ready to appeal to the federal courts re: ISP, as well. A common argument, made by Beyond Nuclear, Don't Waste Michigan et al., Sierra Club, and other Holtec and ISP CISF opponents, such as Fasken Oil and Ranch, even at the current U.S. Court of Appeals for the District of Columbia Circuit level (the second highest court in the land), is that DOE's role as effective title holder (notwithstanding <and/or licensee title holders> as a fig leaf and afterthought to the contrary) makes these proposed CISFs by Holtec and ISP illegal, violations of the Nuclear Waste Policy Act of 1982, as Amended. And, as Beyond Nuclear has argued for years, NRC cannot violate the Nuclear Waste Policy Act of 1982, as Amended, without also violating the Administrative Procedure Act.

Here is Beyond Nuclear's press release, with links to certain cited legal documents, announcing its federal court appeal against Holtec's CISF, focused on this particular illegality subject matter:

http://archive.beyondnuclear.org/centralized-storage/2020/6/4/beyond-nuclear-files-federal-lawsuit-challenging-high-level.html

Here is the press release, reproduced in full:

[BEYOND NUCLEAR FILES FEDERAL LAWSUIT CHALLENGING HIGH-LEVEL RADIOACTIVE WASTE DUMP FOR ENTIRE INVENTORY OF U.S. “SPENT” REACTOR FUEL

Source:  Beyond Nuclear http://www.beyondnuclear.org/

NEWS FROM BEYOND NUCLEAR

For immediate release

Contact:

Diane Curran, Harmon, Curran, Spielberg + Eisenberg, LLP, (240) 393-9285, dcurran@harmoncurran.com 

Mindy Goldstein, Director, Turner Environmental Law Clinic, Emory University School of Law, (404) 727-3432, mindy.goldstein@emory.edu 

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear, (240) 462-3216, kevin@beyondnuclear.org 

Stephen Kent, KentCom LLC, (914) 589 5988, skent@kentcom.com


BEYOND NUCLEAR FILES FEDERAL LAWSUIT CHALLENGING HIGH-LEVEL RADIOACTIVE WASTE DUMP FOR ENTIRE INVENTORY OF U.S. “SPENT” REACTOR FUEL   

Petitioner charges the Nuclear Regulatory Commission knowingly violated U.S. Nuclear Waste Policy Act and up-ended settled law prohibiting transfer of ownership of spent fuel to the federal government until a permanent underground repository is ready to receive it

[WASHINGTON, DC – June 4, 2020] -- Today the non-profit organization Beyond Nuclear filed an appeal with the U.S. Court of Appeals for the District of Columbia Circuit requesting review of an  April 23, 2020 order and an October 29, 2018 order by the U.S. Nuclear Regulatory Commission (NRC), rejecting challenges to Holtec International/Eddy-Lea Energy Alliance’s application to build a massive “consolidated interim storage facility” (CISF) for nuclear waste in southeastern New Mexico. Holtec proposes to store as much as 173,000 metric tons of highly radioactive irradiated or “spent” nuclear fuel – more than twice the amount of spent fuel currently stored at U.S. nuclear power reactors – in shallowly buried containers on the site.   

But according to Beyond Nuclear’s petition, the NRC’s orders “violated the Nuclear Waste Policy Act and the Administrative Procedure Act  by refusing to dismiss an administrative proceeding that contemplated issuance of a license permitting federal ownership of used reactor fuel at a commercial fuel storage facility.”

Since it contemplates that the federal government would become the owner of the spent fuel during transportation to and storage at its CISF, Holtec’s license application should have been dismissed at the outset, Beyond Nuclear’s appeal argues. Holtec has made no secret of the fact that it expects the federal government will take title to the waste, which would clear the way for it to be stored at its CISF, and this is indeed the point of building the facility. But that would directly violate the 1982 Nuclear Waste Policy Act (NWPA), which prohibits federal government ownership of spent fuel unless and until a permanent underground repository is up and running.  No such repository has been licensed in the U.S. The U.S. Department of Energy’s (DOE) most recent estimate for the opening of a geologic repository is the year 2048 at the earliest.

In its April 23 decision, in which the NRC rejected challenges to the license application, the four NRC Commissioners admitted that the NWPA would indeed be violated if title to spent fuel were transferred to the federal government so it could be stored at the Holtec facility.  But they refused to remove the license provision in the application which contemplates federal ownership of the spent fuel. Instead, they ruled that approving Holtec’s application in itself would not involve NRC in a violation of federal law, and that therefore they could go forward with approving the application, despite its illegal provision. According to the NRC’s decision, “the license itself would not violate the NWPA by transferring the title to the fuel, nor would it authorize Holtec or [the U.S. Department of Energy] to enter into storage contracts.” (page 7). The NRC Commissioners also noted with approval that “Holtec hopes that Congress will amend the law in the future.” (page 7).

“This NRC decision flagrantly violates the federal Administrative Procedure Act (APA), which prohibits an agency from acting contrary to the law as issued by Congress and signed by the President,” said Mindy Goldstein, an attorney for Beyond Nuclear. “The Commission lacks a legal or logical basis for its rationale that it may issue a license with an illegal provision, in the hopes that Holtec or the Department of Energy won’t complete the illegal activity it authorized. The buck must stop with the NRC.”   

“Our claim is simple,” said attorney Diane Curran, another member of Beyond Nuclear’s legal team. “The NRC is not above the law, nor does it stand apart from it.”

According to a 1996 D.C. Circuit Court ruling, the NWPA is Congress’ “comprehensive scheme for the interim storage and permanent disposal of high-level radioactive waste generated by civilian nuclear power plants” [Ind. Mich. Power Co. v. DOE, 88 F.3d 1272, 1273 (D.C. Cir. 1996)]. The law establishes distinct roles for the federal government vs. the owners of facilities that generate spent fuel with respect to the storage and disposal of spent fuel. The “Federal Government has the responsibility to provide for the permanent disposal of … spent nuclear fuel” but “the generators and owners of … spent nuclear fuel have the primary responsibility to provide for, and the responsibility to pay the costs of, the interim storage of … spent fuel until such … spent fuel is accepted by the Secretary of Energy” [42 U.S.C. § 10131]. Section 111 of the NWPA specifically provides that the federal government will not take title to spent fuel until it has opened a repository [42 U.S.C. § 10131(a)(5)].  

“When Congress passed the Nuclear Waste Policy Act and refused to allow nuclear reactor licensees to transfer ownership of their irradiated reactor fuel to the DOE until a permanent repository was up and running, it acted wisely,” said Kevin Kamps, radioactive waste specialist for Beyond Nuclear. “It understood that spent fuel remains hazardous for millions of years, and that the only safe long-term strategy for safeguarding irradiated reactor fuel is to place it in a permanent repository for deep geologic isolation from the living environment. Today, the NWPA remains the public’s best protection against a so-called ‘interim’ storage facility becoming a de facto permanent, national, surface dump for radioactive waste. But if we ignore it or jettison the law, communities like southeastern New Mexico can be railroaded by the nuclear industry and its friends in government, and forced to accept mountains of forever deadly high-level radioactive waste other states are eager to offload.”

In addition to impacting New Mexico, shipping the waste to the CISF site would also endanger 43 other states plus the District of Columbia, because it would entail hauling 10,000 high risk, high-level radioactive waste shipments on their roads, rails, and waterways, posing risks of radioactive release all along the way.

Besides threatening public health and safety, evading federal law to license CISF facilities would also impact the public financially. Transferring  title and liability for spent fuel from the nuclear utilities that generated it to DOE would mean that federal taxpayers would have to pay for its so-called "interim" storage, to the tune of many billions of dollars.  That’s on top of the many billions ratepayers and taxpayers have already paid to fund a permanent geologic repository that hasn’t yet materialized. 

But that’s not to say that Yucca Mountain would be an acceptable alternative to CISF. “A deep geologic repository for permanent disposal should meet a long list of stringent criteria: legality, environmental justice, consent-based siting, scientific suitability, mitigation of transport risks, regional equity, intergenerational equity, and safeguards against nuclear weapons proliferation, including a ban on spent fuel reprocessing,” Kamps said. “But the Yucca Mountain dump, which is targeted at land owned by the  Western Shoshone in Nevada, fails to meet any of those standards.  That’s why a coalition of more than a thousand environmental, environmental justice, and public interest organizations, representing all 50 states, has opposed it for 33 years."

Kamps noted that the U.S. Court of Appeals for the District of Columbia Circuit has upheld the NWPA before, including in the matter of inadequate standards for Yucca Mountain.  In its landmark 2004 decision in Nuclear Energy Institute v. Environmental Protection Agency, it wrote, “Having the capacity to outlast human civilization as we know it and the potential to devastate public health and the environment, nuclear waste has vexed scientists, Congress, and regulatory agencies for the last half-century."  The Court found the U.S. Environmental Protection Agency’s insufficient 10,000-year standard for Yucca Mountain violated the NWPA’s requirement that the National Academy of Sciences' recommendations must be followed, and ordered the EPA back to the drawing board. In 2008, the EPA issued a revised standard, acknowledging a million-year hazard associated with irradiated nuclear fuel and high-level radioactive waste. Even that standard falls short, Kamps said, because certain radioactive isotopes in spent fuel remain dangerous for much longer than that.  Iodine-129, for example, is hazardous for 157 million years. 

NOTE TO EDITORS AND PRODUCERS:  Sources quoted in this release are available for comment.  For a copy of the petition filed today, to arrange interviews or for other information, please contact Stephen Kent, skent@kentcom.com, 914-589-5988

-30-

Beyond Nuclear is a 501(c)(3) nonprofit membership organization. Beyond Nuclear aims to educate and activate the public about the connections between nuclear power and nuclear weapons and the need to abolish both to safeguard our future. Beyond Nuclear advocates for an energy future that is sustainable, benign and democratic. The Beyond Nuclear team works with diverse partners and allies to provide the public, government officials, and the media with the critical information necessary to move humanity toward a world beyond nuclear. Beyond Nuclear: 7304 Carroll Avenue, #182, Takoma Park, MD 20912. Info@beyondnuclear.org. www.beyondnuclear.org.]

As mentioned above, if and when the NRC Commissioners likewise reject Beyond Nuclear's appeals in the ISP licensing proceeding, we stand ready to appeal that ruling to the federal courts.

Please address and rectify your woefully inadequate "hard look" under NEPA, re: this health-, safety-, and environmentally-significant, as well as legally-binding, subject matter above.

And please acknowledge your receipt of these comments, and confirm their inclusion as official public comments in the record of this docket.

Thank you.

Sincerely,

Kay Drey, President, Board of Directors, Beyond Nuclear

and

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear
Friday
Oct232020

Beyond Nuclear's 20th set of public comments, re: Docket ID NRC-2016-0231, and report number NUREG-2239, NRC's ISP/WCS CISF DEIS,re: Stringent Criteria for a Highly Radioactive Waste Geologic Repository; 1,000+ organizations opposed to the Yucca dump targeted at Western Shoshone land in NV

Submitted via: <WCS_CISF_EIS@nrc.gov>

Dear NRC Staff,

We submit these comments on behalf of our members and supporters, not only in New Mexico and Texas, near the targeted ISP/WCS CISF site, but across both of these states, and the rest of the country, along road, rail, and waterway routes that would be used for high risk, highly radioactive waste shipments to ISP/WCS's CISF, as well as to Yucca Mountain, Nevada, on Western Shoshone land -- wrongly and illegally assumed by ISP/WCS, as well as by NRC, to someday (or some decade, or some century) become a permanent disposal repository. This unnecessarily repeated, multiple legged, cross-continental transport of highly radioactive waste, is another significant aspect of the EJ (Environmental Justice) burden associated with this ISP/WCS CISF scheme.

The following subject matter has gotten little to no attention in NRC's ISP/WCS CISF DEIS, a far cry from NEPA's legally binding "hard look" requirement:

Stringent Criteria for a Highly Radioactive Waste Geologic Repository; 1,000+ organizations opposed to the Yucca dump targeted at Western Shoshone land in NV

Please take into consideration the list of "Stringent Criteria for a Highly Radioactive Waste Geologic Repository," which I prepared several months ago, below. In order to legitimately open a safe, sound, publicly accepted permanent geologic repository, one that is protective of health, safety, and the environment, DOE (actually, NOT DOE -- its replacement -- see just below) will need to identify a location that meets all of these stringent criteria, and, as mentioned at the end, perhaps others yet to be identified.
Actually, not DOE -- but a replacement agency or institution. For, just as consent-based siting was listed as a top final recommendation by the Blue Ribbon Commission on America's Nuclear Future Final Report in Jan., 2012, so too was replacement of DOE in this role, as DOE has garnered so much public distrust over these and related matters, that the damage to trust is permanent and irreparable, and DOE must be replaced. (Of course, much the same could be said of NRC, as well.)
I provide this listing, as promised in earlier comments I've submitted in this proceeding, in order to show that the proposed Yucca Mountain, Nevada dump-site violates many, to most, to all of these criteria. But not only should Yucca Mountain be removed from any further consideration for a permanent dump-site, it will be removed. Why? Because the Western Bands of the Shoshone Nation of Indians, the State of Nevada, and more than a thousand environmental, environmental justice, social justice, and public interest organizations, representing many millions of American members, demand it, just as they have for 33 years and counting, ever since passage of the infamous "Screw Nevada" Act of 1987, the Nuclear Waste Policy Amendments Act of 1987, which singled out Yucca Mountain as the only site in the country for further consideration as a permanent repository. Beneath the following "Stringent Criteria" listing, I have also included a partial listing of the 1,000-group+ environmental, justice, and public interest coalition, representing every state, that is adamantly opposed to the Yucca dump.

Thus, for all of these reasons, ISP/WCS's and NRC's assumption that Yucca Mountain will someday become a permanent repository, is bogus, illegal, erroneous, wrong, unacceptable, and improper. Neither ISP/WCS nor NRC can justify calling this proposed CISF "temporary" or "interim." If it is licensed, constructed, and operated, it will certainly become very long-term surface storage, likely indefinite, and perhaps even de facto permanent -- a surface storage/disposal parking lot dump.

Citations (linked immediately below; reproduced in full, further below):

Stringent Criteria for a Highly Radioactive Waste Geologic Repository

<http://archive.beyondnuclear.org/repositories/2020/5/26/stringent-criteria-for-a-highly-radioactive-waste-geologic-r.html>;

1,000+ organizations opposed to the Yucca Mountain dump targeted at Western Shoshone Land in Nevada

<http://archives.nirs.us/radwaste/yucca/yuccaopponentslist.htm>

[a partial listing -- the resistance has expanded since 2002].

Of course, transporting high-risk, high-level radioactive waste once, instead of multiple times, makes good sense. Thus, CISFs make no sense. Irradiated nuclear fuel should be transported only once, from the nuclear power plant sites where it is currently located, to a permanent repository. But that permanent repository must meet all of the stringent criteria listed above. Yucca Mountain cannot do so. Therefore, Holtec and NRC should stop illegally and improperly assuming it will do so. If Holtec and NRC refuse to stop, then Yucca dump opponents -- the Western Shoshone, the State of Nevada, and more than a thousand environmental and public interest groups, representing many millions of people -- will see to it that Holtec and NRC are stopped, just as the adamant resistance to the Yucca dump has stood strong for 33 years, and counting.

So, for the irradiated nuclear fuel that already exists, geologic isolation, at a site meeting all the stringent criteria above, is the preferred alternative to Holtec's CISF in NM.

For the irradiated nuclear fuel that does not already exist, the preferred alternative to Holtec's CISF in NM, is to not generate it in the first place. Dangerously age-degraded reactors should be shut ASAP for safety's sake alone. Proposed new reactors should be cancelled, and no new reactors built in the future. The electricity supply for replacing these shutdown old, and cancelled proposed new, reactors should be provided by energy efficiency and conservation savings in the first place, and any newly or otherwise needed electricity should be provided, instead of by nuclear power, by ever more clean, safe, secure, reliable, and affordable renewable energy, such as by solar and wind power. 

Please address and rectify your woefully inadequate "hard look" under NEPA, re: this health-, safety-, and environmentally-significant, as well as legally-binding, subject matter above.

And please acknowledge your receipt of these comments, and confirm their inclusion as official public comments in the record of this docket.

Thank you.

Sincerely,

Kay Drey, President, Board of Directors, Beyond Nuclear

and

Kevin Kamps, Radioactive Waste Specialist, Beyond Nuclear

Citations reproduced in full, here below:

Stringent Criteria for a Highly Radioactive Waste Geologic Repository

Prepared by Kevin Kamps (Beyond Nuclear radioactive waste specialist; Don't Waste Michigan board of directors member; Citizens for Alternatives to Chemical Contamination advisory board member)

May 26, 2020

The Earth's surface is such a volatile, fragile, and high-risk location, that our search for a deep geologic repository for permanent isolation of highly radioactive wastes is a critical imperative. (Just as critical is the need to stop the generation of highly radioactive wastes in the first place, since -- even 78 years after Enrico Fermi generated the first highly radioactive wastes during the Manhattan Project, and 63 years after the commencement of operations at the first U.S. "civilian" or commercial reactor, generating irradiated nuclear fuel -- we currently still have no safe, secure, sound, acceptable solution for their permanent disposition.) The basic but stringent criteria, however, which such a candidate geologic repository site would have to meet would include:  

(1) Legality (for example, a proposed site can't violate U.S. treaties with Native American Nations, like the Western Shoshone Treaty of Ruby Valley of 1863; such treaties are the highest law of the land, equal in stature to the U.S. Constitution itself).

(2) Consent-based siting  (the Western Shoshone, and the State of Nevada, do not consent to the Yucca dump; legalized bribery of vulnerable communities also does not constitute "consent"; as Keith Lewis, environmental director of the Serpent River First Nation in Ontario, put it in the book This Is My Homeland: Stories of the effects of nuclear industries by people of the Serpent River First Nation and the north shore of Lake Huron (1998, published by Serpent River First Nation, edited by Serpent River First Nation Members Lorraine Rekmans and Keith Lewis, as well as by Anabel Dwyer), "There is nothing moral about bribing a starving man with money."

(3) Scientific suitability  (that is, isolation of hazardous radioactivity from the living environment for at least a million years -- Yucca can't meet this criteria either, by a long shot! If the Yucca dump were opened, serious leakage to the environment could begin within centuries, but would become large-scale after 11,000 years, this according to DOE's own computer modeling! The leakage would just worsen over longer time periods. It would continue to present a hazard for a million years or more).

(4) Environmental justice  (Newe Sogobia and Nevada can't be targeted again, after decades of nuclear weapons testing fallout, "low" level radioactive waste dumping, etc.).

(5)   Regional equity (no East dumps on West, especially when 90% of the highly radioactive wastes are in the eastern half of the U.S., and 75% is east of the Mississippi River).

(6) Mitigation of transport risks (closely related to regional equity, immediately above).

(7) Inter-generational equity (related to scientific suitability, above -- no double standards, as at the proposed Yucca dump, where the first 10,000 years' "allowable" or "permissible" dose standard is 15 milli-Rem per year, which then is "allowed" or "permitted" to go up to 100 mR/yr after 10,000 years out to a million years -- meaning future generations would face 6.66 times more "allowable"/"permissible" exposure to hazardous radioactivity than current generations!).

(8) Non-proliferation (the risk of the weapons-grade plutonium in the irradiated nuclear fuel being exploited for weapons manufacture is a major reason that perpetual surface storage is not acceptable, and permanent irreversible "disposal" is needed).

(9) Pre-"disposal" reprocessing is unacceptable (given the weapons proliferation risk, the environmental ruination and health damage that would result from large-scale hazardous radioactivity releases, not to mention the astronomical expense, which the public would be forced to pay for).

(10) This list of required strict siting criteria could well expand, as additional concerns come to light. 

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1,000+ organizations opposed to the Yucca Mountain dump targeted at Western Shoshone Land in Nevada

[a partial listing -- the resistance has expanded since 2002]

OVER 50 NATIONAL & 700 STATE/LOCAL ENVIRONMENTAL & PUBLIC INTEREST ORGANIZATIONS OPPOSED TO THE YUCCA MOUNTAIN NUCLEAR WASTE DUMP

National Organizations (51 Total)

Alliance for Nuclear Accountability, Seattle, Washington
American Lands Alliance, Washington, DC
Americans for Democratic Action, Washington, DC
American Rivers, Washington, DC
American Public Health Association, Washington, DC
Center for Safe Energy, Earth Island Institute, Berkeley, California
Clean Water Action, Washington, DC
Defenders of Wildlife, Washington, DC
Earthjustice, Oakland, CA
Environmental Action Foundation, Takoma Park, Maryland
Environmental Defense, New York, NY
Environmental Working Group, Washington, DC
Fellowship of Reconciliation, Nyack, NY
Free the Planet!, Washington, DC
Friends of the Earth, Washington, DC
Government Accountability Project, Seattle, WA
Grandmothers for Peace International, Elk Grove, CA
Great Lakes United (over 160 local groups in Great Lakes states and provinces), Buffalo, NY
Greenpeace , Washington , DC
Honor the Earth, St. Paul, Minnesota
Indigenous Environmental Network, Bemidji, MN
Institute for Energy and Environmental Research, Takoma Park, Maryland
International Association of Fire Fighters, Washington, DC
League of Conservation Voters, Washington, DC
League of United Latin American Citizens, Washington, DC
League of Women Voters of the United States, Washington, DC
National Environmental Coalition of Native Americans, Prague, OK
National Environmental Trust , Washington, DC
National Wildlife Federation, Washington, DC
Natural Resources Defense Council, Washington, DC
Nuclear Information and Resource Service, Washington, DC
Pax Christi USA, Erie, PA
Peace Action, Washington, DC
Physicians for Social Responsibility, Washington, DC
Presbyterian Church ( USA), National Ministries Division, Washington, DC
Psychologists for Social Responsibility, Washington, DC
Public Citizen, Washington, DC
The Safe Energy Communication Council, Washington, DC
Scenic America, Washington, DC
Sierra Club, Washington, DC
Taxpayers for Common Sense, Washington, DC
Union of American Hebrew Congregations/ Religious Action Center of Reform Judaism, Washington, DC
United Church of Christ, Office for Church in Society, Washington, DC
United Electrical, Radio & Machine Workers of America (UE), Alexandria, Virginia
The United Methodist Church, General Board of Church and Society, Washington, DC
U.S. Public Interest Research Group, Washington, DC
The Wilderness Society, Washington, DC
Women's International League for Peace and Freedom, Philadelphia, PA
The Women Legislators’ Lobby (WiLL), Washington, DC
Women's Action for New Directions (WAND), Washington, DC
20/20 Vision, Washington, DC

State and Local Organizations
(Over 700 Total, Representing All 50 States and the District of Columbia)

Alabama Environmental Council, Birmingham, Alabama

Alaska Center for the Environment, Anchorage, Alaska

Air, Water, Earth Organization, Lake Havasu City, Arizona
Alliance of Atomic Veterans, Topock, Arizona
Arizona Citizen Action, Phoenix, AZ
Arizona Safe Energy Coalition, Tucson, Arizona
Black Mesa Indigenous Support, Flagstaff, AZ
DON'T WASTE ARIZONA, INC., Phoenix, Arizona
Environmental Justice Action Group, Tucson, AZ
Flagstaff Activist Network, Flagstaff, Arizona
Flagstaff Opposed to Nuclear Transportation (FONT), Flagstaff, Arizona
GE Stockholders Alliance, Tucson, Arizona
Sky Island Watch, Tucson, Arizona
Southwest Toxic Watch, Tucson, Arizona
Student Environmental Action Coalition, SW, Tucson, Arizona
The Nuclear Resister, "a chronicle of hope", Tucson, Arizona

Women's International League for Peace and Freedom, Tucson, Arkansas
Arkansas WAND, Little Rock, AR
Student Activists that Value the Earth (SAVE), Conroy, Arkansas
The Arkansas Public Policy Panel, Little Rock, Arkansas

Abalone Alliance, San Francisco, California
Alliance for Survival, Costa Mesa, California
Americans for a Safe Future, Santa Monica, California
The Atomic Mirror, Port Hueneme, CA
Awende/S Women’s Native Drum, Auburn, CA
Bay Area Nuclear Waste Coalition, San Francisco, California
Berkeley Women in Black, Berkeley, CA
Butte Environmental Council, Chico, CA
Calaveras County Green Party, Calaveras County, CA
California Alliance in Defense of Residential Environments, Sherman Oaks, CA
California Communities Against Toxics, Rosamond, California
Californians for Radioactive Safeguards, Atherton, California
Call to Action, Santa Cruz, CA
Citizens Along the Roads and Tracks (CART), Sacramento, CA
Climate Action NOW!, Berkeley, CA
Committee to Bridge the Gap, Los Angeles, California
Conference of Social Justice Coordinatord, Los Angeles, CA
Desert Citizens Against Pollution, Lancaster, California
Earth Action Network, Los Angeles, California
Earth Regeneration Society, Berkeley, CA
East Bay Peace Action, Albany, CA
EcoBridge, San Francisco, CA
El Dorado County Green Party, Placerville, CA
Grandmothers for Peace International, Elk Grove, California
Grandmothers for Peace, Sacramento Chapter, Sacramento, CA
Grandmothers for Peace/San Luis Obispo County Chapter, San Miguel, CA
Gray Panthers of LA West, Los Angeles, California
Greenaction for Health and Environmental Justice, San Francisco, CA
Green Party, San Bernardino, CA
Gray Panthers of Sacramento, Sacramento, CA
Healing Global Wounds, Freedom, California
HOME - Healing Ourselves and Mother Earth, Tecopa, CA
Independent Power Providers, North Fork, California
Inland Independent People’s Campaign, Claremont, CA
Life on Planet Earth, Atascadero, California
Los Gatos Unitarian Fellowship, Los Gatos, CA
Nuclear Age Peace Foundation, Santa Barbara, CA
The Nuclear Democracy Network, Bolinas, CA
Nuclear Guardianship Project, Berkeley, CA
Nuclear Weapons Free Zone Commission, Arcata, CA
Occidental Arts and Ecology Center, Occidental, CA
People Against Radioactive Dumping, Needles, CA
Physicians for Social Responsibility, Los Angeles, CA
Physicians for Social Responsibility - Santa Monica, Santa Monica, CA
Bonnie Raitt, ARIA Foundation, Los Angeles, CA
Redbud, Rough and Ready, CA
Redwood Alliance & REEI, Arcata, California
Sacramento Green Party, Sacramento, CA
SF-Bay Area Physicians for Social Responsibility, San Francisco, CA
San Luis Obispo GREEN Party, San Luis Obispo, CA
San Luis Obispo Mothers for Peace, San Luis Obispo, CA
Save Ward Valley, Needles, California
Social Justice Center of Marin, Fairfax, CA
Southern California Abolition 2000, Santa Monica, CA
Students for Social Responsibility, California Polytechnic Institute, San Luis Obispo, CA
The Green Party of Santa Barbara County, Santa Barbara, California
Tri-Valley CAREs (Citizens Against a Radioactive Environment), Livermore, CA
Women's Energy Matters, Berkeley, CA
Women For - Orange County Chapter, Laguna Beach, California

American Friends Service Committee, Colorado Office, Denver, Colorado
Citizens for Peace in Space, Colorado Springs, CO
Colorado Clean Water Action, Denver, CO
Colorado Coalition for the Prevention of Nuclear War, Denver, CO
Connections 2000, Boulder, CO
Environmental Information Network, Inc., Denver, CO
Global Response, Boulder, CO
Peace and Justice Task Force, United Church of Christ, Denver, CO
Physicians for Social Responsibility, Denver, CO
Rocky Mountain Peace and Justice Center, Boulder, Colorado
The Colorado Environmental Seminars, Denver, Colorado
Women's International League for Peace and Freedom, Colorado, Boulder, Colorado

Citizens Awareness Network , CT Chapter, Haddam, Connecticut
Citizens Regulatory Commission, Waterford, Connecticut
Connecticut Coalition Against Millstone, Mystic, CT
Connecticut Green Party, Hartford, Connecticut
Connecticut Opposed to Waste, Broad Brook, Connecticut
Donnelly/Colt, Hampton, CT
Don't Waste Connecticut, New Haven, CT
E3 (Earth, Equality, Education), Middletown, Connecticut
Earth Challenge, Inc., New Haven, Connecticut
Peoples Action for Clean Energy (PACE), Canton, CT
Stonington Chapter of the Connecticut Green Party, Stonington, CT
Toxics Action Center, West Hartford, Connecticut

Green Delaware, Port Penn, Delaware
Green Party of Delaware, Newark, DE
Student Environmental Action Coalition, U. of Delaware
Students for the Environment, University of Delaware, Newark, DE

Environmental and Peace Education Center, Fort Myers, Florida
Florida Coalition for Peace and Justice, Gainesville, Florida
Lower Florida Keys Women's International League for Peace and Freedom, Summerland Key, Florida
Physicians for Social Responsibility, Ft. Pierce, FL
U. of Florida Environmental Action Group, Gainesville, FL

Alternatives In Action!, Atlanta, Georgia
Action for a Clean Environment, Alto, Georgia
Campaign for a Prosperous Georgia, Savannah, GA
Food Not Bombs, Atlanta GA
Georgians Against Nuclear Energy, Atlanta, Georgia
Grandmothers for Peace/Southeast Chapter, Alpharetta, GA
Physicians for Social Responsibility – Atlanta, Atlanta, GA
Sierra Club, Atlanta, GA
Women's Action for New Directions/Atlanta, Atlanta, GA

Irradiation Free Food Hawaii, Big Island of Hawaii, Hawaii
Life of the Land, Honolulu, HI

Downwinders, Lava Hot Springs, Idaho
Environmental Defense Institute, Troy, Idaho
Snake River Alliance, Idaho Falls, ID

Body Wisdom Incorporated, Lake Bluff, Illinois
Chicago Media Watch, Chicago, Illinois
Chicago Greens, Chicago, IL
Coalition for Nuclear Justice, Brookport, IL
Committee for New Priorities, Chicago, IL
Environmental Concerns Organization (E.C.O.), DePaul University, Chicago, IL
Illinois Student Environmental Network, Urbana, IL
Lake County Conservation Alliance, Grayslake, IL
Lake County Green Party, Mundelein, IL
Northwestern University Students for Ecological and Environmental Development (SEED), Evanston, IL
Nuclear Energy Information Service, Evanston, Illinois
Nuclear-Free Great Lakes Campaign, Evanston, IL
Prairie Alliance, Dahinda, IL
Regional Association of Concerned Environmentalists, Brookport, IL
Rogers Park Greens, Chicago, IL
USASC Justice and Peace Office, Red Bud, IL

Citizens Action Coalition of Indiana, Indianapolis, Indiana
Community Times, West Lafayette, IN
Heartwood, Bloomington, IN
Hoosier Environmental Council, Indianapolis, IN
Michiana Earth Day, South Bend, IN
St. Joseph Valley Greens, South Bend, IN
Tippecanoe Environmental Council, West Lafayette, IN
Valley Watch, Inc., Evansville, Indiana

Integrative Educational Systems, Ames, Iowa
EarthCare, Des Moines, IA
owa Citizen Action Network, Des Moines, IA
Iowa City/Johnson County Green Party, Iowa City, Iowa
Iowa Farmers Union, Clear Lake, IA
Iowans for Nuclear Safety, Cherokee, Iowa
Iowa Renewable Energy Association, Muscatine, IA
Iowa Sustainable Energy for Economic Development (SEED) Coalition, Iowa City, IA
Student Environmental Action Coalition, U. of Northern Iowa

Enviro-Health Concerns, Witchita, Kansas
Kansas Natural Resource Council, Topeka, KS
Physicians for Social Responsibility/Kansas, Witchita, KS
The Southwind Group, Lawrence, Kansas
Wolf Creek Citizens Watchdog Group, Lawrence, Kansas

Appalachia Science in the Public Interest, Mt. Vernon, Kentucky
Chemical Weapons Working Group, Berea, KY
Citizens Environmental Defense League, Bowling Green, KY
Coalition for Health Concern, Benton, KY
Common Ground, Berea, KY
Kentucky Environmental Foundation, Berea, KY
Non-Stockpile Chemical Weapons Citizen Coalition, Berea, KY
Yggdrasil Institute, Georgetown, KY

Safe Schools, Lafeyette, Louisiana
Alliance for Affordable Energy, New Orleans, LA

Cheaper, Safer Power, Portland, Maine
Earth Day Commitment, Edgecomb, Maine
Friends of the Coast Opposing Nuclear Pollution, Wiscasset, ME
Woolwich Greens, Woolwich, ME

Alternative Press Center, Baltimore, Maryland
DC Solar, College Park, Maryland
Maryland Safe Energy Coalition, Baltimore, MD
Nuclear Free Takoma Park Committee, Takoma Park, MD
SERV, Kensington, MD

Citizen Awareness Network, Shelburne Falls, Massachusetts
Citizens at Risk, Cape Cod, MA
C-10 Research and Education Foundation, Newburyport, MA
Don't Waste Massachusetts, Duxbury, Massachusetts
Massachusetts Citizens For Safe Energy, Boston, Massachusetts
MetroWest WAND, Hopkinton and Woodville, MA
Post Cassini Flyby News, Wendell Depot, MA
WAND and Mass Action for Women, Natick, MA
Women’s Action for New Directions, Amesbury, MA
Women’s Action for New Directions, Mt. Holyoke College, South Hadley, MA
Women's Action for New Directions of Western Massachusetts, Amherst, Massachusetts

Bertha Cappan Reynolds Society/Social Workers for Justice Western Michigan University, Kalamazoo, Michigan
BOND—Border Opposes Nuclear Dump, Temperance, MI
Chernobyl Children's Project, Kalamazoo, Michigan
Citizens for Alternatives to Chemical Contamination, Lake, MI
Citizens for a Healthy Planet, Emmett, Michigan
Citizens for Environmental Protection, Niles, Michigan
Citizens' Resistance at Fermi Two, Monroe, MI
Coalition for a Nuclear Free Great Lakes, Monroe, MI
Don't Waste Michigan, Grand Rapids, Michigan
EnvOrg Student Environmental Organization, Kalamazoo, Michigan
Kalamazoo Area Coalition for Peace and Justice, Kalamazoo, Michigan
Leonard Peltier Support Group, Pavilion Township, Michigan
Lone Tree Council, Bay City, MI
Michigan Environmental Council (representing over 50 groups), Lansing, MI
Non-Violent Student Organization, Kalamazoo College, Kalamazoo, Michigan
Northwoods Wilderness Recovery, Marquette, MI
Palisades Watch, Kalamazoo, Michigan
People's Food Co-Op, Kalamazoo, Michigan
Positives for Peace and Environmental Justice, Niles, MI
Professional Inventor's Alliance, Grand Blanc, Michigan
Radiological Evaluation & Action Project, Great Lakes , Ewen, MI
Students for a Sustainable Earth, Western Michigan University, Kalamazoo, Michigan
West Michigan Environmental Action Council, Grand Rapids, Michigan
Women’s Action for New Directions, Ann Arbor, MI
Women’s Action for New Directions-Metro Detroit, Southfield, MI
World Tree Center for Peace, Justice and Mother Earth, Kalamazoo, Michigan

Bottineau Citizens In Action, Minneapolis, Minnesota
Clean Water Action Alliance of Minnesota, Minneapolis, Minnesota
Communities United for Responsible Energy, Lake City/Frontenac, Minnesota
Duluth-Superior FOR, Duluth, MN
Home Owners on the Mississippi for the Eco-System (HOMES), Minneapolis, MN
Institute for Local Self-Reliance, Minneapolis, MN
Mankato Area Environmentalists, Mankato, MN
MN-WEB (Minnesota Women's Earth Brigade), Minneapolis, MN
Minnesotans for an Energy-Efficient Economy, Saint Paul, Minnesota
Mississippi Corridor Neighborhood Coalition, Minneapolis, MN
North American Water Office, Lake Elmo, Minnesota
Prairie Island Coalition, Lake Elmo, Minnesota
Sunrise Alternatives, Cannon Falls, MN

Mississippi 2020 Network, Inc., Jackson, Mississippi

Citizens Against Radioactive Transport, Webster Groves, MO
Kansas City Greens, Kansas City, Missouri
Mid-Missouri Peaceworks, Columbia, MO
Mississippi River Basin Alliance, St. Louis, MO
Missouri Coalition for the Environment, St. Louis, Missouri
Sierra Club, Jeff. City, MO

Missoula Women for Peace, Missoula, Montana
Native Forest Network -- West, Missoula, Montana
Women’s Action for New Directions, Missoula, MT

Nebraskans for Peace, Lincoln, Nebraska
Sierra Club, Lincoln, NE
South Salt Creek Community Organization, Lincoln, NE
Western Nebraska Resources Council, Chadron, NE

Alliance of Atomic Veterans, Atomic Workers Division, Las Vegas, NV
Alliance for Worker's Rights, Reno, Nevada
Campaign for Nevada’s Future, Las Vegas, NV
Citizen Alert, Las Vegas, Nevada
Citizens Against Nuclear Waste in Nevada (CANWIN), Carson City, NV
Clark County Greens, Las Vegas, NV
Friends of Nevada Wilderness, Las Vegas, NV
Great Basin Mine Watch, Reno, NV
Nevada Desert Experience, Las Vegas, Nevada
Nevada Empowered Women's Project, Reno, Nevada
Nevada Green Party, Reno, NV
Nevada Nuclear Waste Task Force, Las Vegas, Nevada
Nevada Wilderness Project, Reno, NV
National Environmental Trust, Las Vegas, NV
Nuclear Risk Management For Native Communities, Duckwater, NV
Progressive Leadership Alliance of Nevada, Las Vegas, Nevada
Public Resource Associates, Reno, Nevada
Rural Alliance For Military Accountability, Reno, Nevada
Sierra Club, Toiyabe Chapter, Las Vegas, NV
Truckee River Yacht Club, Reno, Nevada
Western Shoshone Defense Project, Crescent Valley, NV
Yucca Mountain Raggers, Las Vegas, NV

Good Money, Inc., Dover, New Hampshire
New Hampshire Peace Action, Concord, New Hampshire
Seacoast Anti-Pollution League, Portsmouth, NH

Coalition Against Toxics, Marlton, New Jersey
Coalition for Peace & Justice, Cape May, New Jersey
Grass Roots Environmental Organization of New Jersey, Flanders, New Jersey
Green Party of New Jersey, Trenton, New Jersey
Jersey Shore Nuclear Watch, Brick, NJ
NJ/NY Environmental Watch, Elizabeth, NJ
Oyster Creek Nuclear Watch, Island Heights, New Jersey
Stockton Peace Action, Richard Stockton College, Pomona, NJ
UNPLUG Salem, Linwood, NJ

Albuquerque Center for Peace and Justice, Albuquerque, New Mexico
Citizen Action of New Mexico, Albuquerque, NM
Citizens for Alternatives to Radioactive Dumping, Albuquerque, NM
Concerned Citizens for Nuclear Safety, Santa Fe, NM
Humans Against Nuclear Waste Dumps, Mescalero, Ruidoso, NM
Kwanitewk Native Resource Network, Meriden, NM
Los Alamos Study Group, Santa Fe, NM
Nuclear Watch of New Mexico, Santa Fe, NM
Peace Action New Mexico, Santa Fe, New Mexico
Progressive Student Alliance of the University of New Mexico, Albuquerque, New Mexico
Southwest Research and Information Center, Albuquerque, New Mexico
Tribal Environmental Watch Alliance, Espanola, NM
Water Information Network, Albuquerque, NM

Alliance to Close Indian Point, Ossining, New York
Beacon Sloop Club
Bronx Greens, Bronx, NY
CAN DO (Citizens Against Nuclear Energy – Dobbs Ferry)
Chappaqua Against Nuclear Generated Power (CHANGE)
Chenango North Energy Awareness Group, South Plymouth, New York
Citizens Awareness Network/Central New York, Syracuse, New York
Citizens’ Environmental Coalition, Albany, NY
Citizens for Safe Energy
Clearwater Hudson River Sloop, Poughkeepsie, NY
Coalition on West Valley Nuclear Wastes, Concord, NY
Communities United For Responsible Energy
Council on Intelligent Energy & Conservation Policy
Croton Close Indian Point Group
Economists Allied for Arms Reduction, Pearl River, NY
Environmental Advocates, Albany, New York
EnviroVideo, Tilden, NY
F.A.C.T.S. (For A Clean Tonawanda Site), Inc., Kenmore, NY
Fingerlake Citizens for the Environment, Waterloo, NY
Fish Unlimited, Shelter Island, New York
Fishkill Ridge Community Heritage
Genesee Valley-Rochester Greens, Rochester, NY
Global Resource Action Center for the Environment (GRACE), New York, New York
Green Party of Erie County, Buffalo, NY
Green Party of the Lower Hudson Valley, NY
Green Party of Onondaga County, Syracuse, NY
Group for the South Fork, Bridgehampton, NY
Hogarth Center for Social Action, Manhattanville College
Irvington Neighbors Against Indian Point
Lawyers’ Committee for Nuclear Policy, New York, NY
Long Island SHAD, Huntington, NY
Metro New York Peace Action Council, New York, New York
New York City Campaign to Close Indian Point
New York City SAFE (Seeking Alternatives for the Environment)
New York City WAND, New York, NY
New York City Citizen’s Awareness Network, Brooklyn, NY
New York City Physicians for Social Responsibility
New York Public Interest Research Group (NYPIRG)
New York State Greens/Green Party, Flushing, NY
NGO Committee on Disarmament, New York, NY
No Escape, Peekskill, NY
Nuclear Free Hudson
Nuclear Free New York, Huntington, New York
Pace Energy Project
Peconic Green Party, Eastern Long Island, NY
Peoples Video Network, New York, New York
Philipstown League for the Environment and Safe Energy (PLEASE)
Physicians for Life, Watermill, NY
Project Edna (engaged democracy for the nuclear age), Brooklyn, NY
Riverkeeper, Inc.
Rockland Citizens Awareness Network
Rockland County Civic Association
Rockland County Conservation Association
Scenic Hudson
Sprayno Coalition
Sierra Club, Atlantic Chapter
Sierra Club, Lower Hudson Group
Sound Shore Safe Energy Advocates (SSSEA)
STAR (Standing for Truth About Radiation), East Hampton, New York
Student Environmental Action Coalition (SEAC), Syracuse, NY
Sustainable Energy Alliance of Long Island, Bridgehampton, NY
Syracuse Food Not Bombs, Syracuse, New York
Syracuse Nuclear Action Group, Syracuse, New York
Temple Beth El Social Action Committee, Tonawanda, NY
UFTbr /S 108 Chapter, Brooklyn, NY
United Bronx Environmental Coalition
Utica Citizens in Action, Utica, NY
War & Peace Foundation, New York, New York
Waterkeeper Alliance
Westchester Green Party, Northwest
WESPAC (Westchester People's Action Coalition), White Plains, NY
Westchester Residents Advocating for Improved Neighborhoods (WRAIN)
Westchester SAFE (Seeking Alternatives for the Environment)
Western New York Peace Center, Working Group on Disarmament, Buffalo, NY
Working Group on Disarmament of the Western New York Peace Center, Buffalo, New York
Women’s Action for New Directions, Brooklyn, NY
Women's Environment & Development Organization, New York, New York
Women's International League for Peace and Freedom, NY Metro, New York, New York
Yorktown Close Indian Point Group

Active Students for a Healthy Envronment, Asheville, North Carolina
Anson County Citizens Against Chemical Toxins in Underground Storage (CACTUS), Clemmons, NC
Blue Ridge Environmental Defense League, Glendale Springs, North Carolina
Chapel Hill Greens Party, Chapel Hill, NC
Communities for Sustainable Forestry, Union Mills, NC
Conservation Council of North Carolina, Raleigh, NC
Durham/Chapel Hill Women’s International League for Peace and Freedom, Durham, NC Haywood Peace Fellowship, Waynesville, NC
Long Branch Environmental Education Center, Leicester, North Carolina
NC Citizens Research Group, Inc., Durham, NC
North Carolina Waste Awareness and Reduction Network (NC WARN), Raleigh-Durham, NC
Orange County Greens, NC
Protect All Children's Environment, Marion, NC
Triangle Chapter Physicians for Social Responsibility, Raleigh, NC
Western North Carolina Alliance, Asheville, NC

North Dakota Clean Water Action, Fargo, North Dakota

Citizens Protecting Ohio (C-Pro), Bexley, Ohio
Cleveland Peace Action, Cleveland, OH
Coalition for a Safe Environment, Toledo, OH
Congress of the Greens/Green Party USA, Cleveland, OH
Earth Day Coalition, Cleveland, Cleveland, Ohio
Environmental Health Watch, Cleveland, OH
Fernald Residents for Environment, Safety & Health, Fernald, OH
Green Environmental Coalition, Yellow Springs, OH
Green Party of Cuyahoga County, Cleveland, OH
Green Party of Ohio, Cleveland, OH
HELP the Environment, Walbridge, OH
Northeast Ohio Greens, Columbia Station, OH
Ohio Citizen Action, Cleveland, OH
Ohio Greens Anti-Nuclear Organizing Committee, Cleveland, OH
Toledo Coalition for Safe Energy, Toledo, OH
Walk Across America for Mother Earth, Columbus, Ohio
Wilmington College Peace Resource Center, Wilmington, Ohio
Women Speak out for Peace & Justice, Women's Int'l League for Peace & Freedom, Cleveland Branch

Citizens Action for Safe Energy, Claremore, OK
Coalition for Environmental Awareness, Newkirk, OK
Earth Concerns of OK (ECO), Tulsa, Oklahoma
EcoLaw Institute, Tahlequah, OK
National Environmental Coalition of Native Americans, Prague, Oklahoma
Oklahoma Toxics Campaign, Guthrie, OK
Oklahomans United, Oklahoma City, OK
Our Earth, University of Oklahoma, Norman, OK
Student Action Network, University of Oklahoma, Norman, OK

Center for Energy Research, Salem, Oregon
Columbia Riverkeeper, Hood River, OR
Don't Waste Oregon, Boring, Oregon
HANFORD WATCH, Portland, Oregon
Indigenous Support Coalition of Oregon, Eugene, Oregon
Northwest Environmental Advocates, Portland, Oregon
Northwest Veterans for Peace, Milwaukie, Oregon
Nuclear Free America, Salem, OR
Oregon Conservancy Foundation, Portland, OR
Oregon Peaceworks, Salem, Oregon
Pacific Party of Oregon (Greens), Portland, Oregon
Southern Oregon Forest Coalition, Medford, OR
United Methodist Church, Salem, OR

Activists' Center for Training In Organizing and Networking (ACTION), Philadelphia, PA
Allegheny Green Party, Strattonville, Pennsylvania
Central Pennsylvania Citizens for Survival, State College, Pennsylvania
Citizen Power, Pittsburgh, PA
Clean Air Council, Philadelphia, PA
Communities for Sustainable Forestry, Kane, PA
Concerned Citizens for SNEC Safety, Six Mile Run, PA
Eco-Action, Penn State University
Environmental Coalition on Nuclear Power, State College, Pennsylvania
Green Party of Pennsylvania, Lancaster, Pennsylvania
Greens of Philadelphia, Philadelphia, Pennsylvania
McKean County Citizens Against Nuclear Waste, Bradford, PA
No Nukes, Harrisburg, Pennsylvania
Northeast Pa. Audubon Society, Honesdale, Pennsylvania
Pennsylvania Citizen Action Network, Reading, PA
Pennsylvania Consumers Action Network, Philadelphia, Pennsylvania
Pennsylvania Environmental Network, Blossburg, PA
Philadelphia Solar Energy Association (PSEA), Philadelphia, Pennsylvania
PROACT, Kane, PA
R.E.S.C.U.E., Nicholson, Pennsylvania
Stop the Organizations Raping Mankind, Seneca, PA
Three Mile Island Alert, Harrisburg, Pennsylvania
Voices of Central Pennsylvania, State College, Pennsylvania
Women in Black, Lancaster Group, Lancaster, Pennsylvania
Women’s International League for Peace and Freedom-Main Line Branch, Haverford, PA

Appalachian Mountain Club, Providence, Rhode Island
Citizen's League for Environmental Action and Recovery (CLEAR), Manville, Rhode Island
Clean Water Action, Providence, RI
Coalition for Consumer Justice, Jamestown, RI

Carolina Peace Resource Center, Columbia, South Carolina

Bison Land Resource Center, Brookings, South Dakota
Lakota Kammerer Foundation, Rapid City, SD
South Dakota Resources Coalition

Coalition for a Healthy Environment, Knoxville, Tennessee
Oak Ridge Environmental Peace Alliance, Oak Ridge, Tennessee
Green Party of Tennessee, Knoxville, TN
Physicians for Social Responsisbility, Knoxville, Tennessee
Tennessee Citizen Action, Nashville, TN
Tennessee Valley Energy Reform Coalition, Knoxville, TN
War Resisters League/Nashville, Nashville, TN

Austin Greens, Austin, Texas
Bastrop County Environmental Network, Bastrop, Texas
Border Environmental Network, Alpine, Texas
Chambers Appraisal Service, Odessa, Texas
Downwinders at Risk, Duncanville, TX
El Paso Chapter, National Lawyer's Guild, El Paso, Texas
El Paso Solar Energy Association, El Paso, Texas
Grandmothers and Mothers Alliance for the Future, Austin, Texas
Mothers Organized to Stop Environmental Sins (MOSES), Dallas, Texas
Peace Farm, Amarillo, TX
SEED Coalition, Austin, Texas
Senior Citizens Alliance of Tarrant County, Political Action Committee, Ft. Worth, TX
Sierra Blanca Legal Defense Fund, Sierra Blanca, Texas
Southwest Workers Union, San Antonio, TX
STAND (Serious Texans Against Nuclear Dumping), Amarillo, Texas
Texas Alliance for Human Needs, Austin, TX

Citizens Against Radioactive Waste in Utah, Salt Lake City, Utah
Escalante Wilderness Project, Escalante, UT
Families Against Incinerator Risk, Salt Lake City, UT
HEAL Utah, Salt Lake City, UT
Living Rivers, Moab, UT
Shundahai Network, Salt Lake City, UT
Utah Peace Test, Salt Lake City, UT

Citizens Awareness Network, Johnson, VT
Native Forest Network, Eastern North America, Burlington, Vermont
New England Coalition on Nuclear Pollution, Brattleboro, Vermont
Peace and Justice Center, Burlington, VT
Rural Vermont, Montpelier, VT
Solar Action for Vermont, Townsend, Vermont
Vermont Citizens Awareness Network, Dummerston, VT

Earth Lodge/Gray Panthers, Manassas Park, Virginia
Nurses.Net, Woodbridge, VA
Taking Responsibility for the Earth and the Environment, Blacksburg, Virginia
Virginia Consumer Action, Virginia

Environmental Center, Western Washington University, Bellingham, Washington
Friends of the Earth, Seattle, WA
HEAL (Hanford Education Action League), Spokane, Washington
Heart of America Northwest, Seattle, WA
Mangrove Action Project, Port Angeles, WA
The Radioactivist Campaign, Belfair, WA
Waste Action Project, Seattle, Washington

Dorothy Day Catholic Worker, Washington, DC
Eco Sense, American U., Washington, DC
Native Youth Alliance, Washington, DC
Power Shift, Washington, DC
Proposition One Committee, Washington, DC
Voices Opposed to Environmental Racism, Washington, DC

Ohio Valley Environmental Coalition, Huntington, West Virginia
West Virginia Citizen Action Group, Charleston, WV

Grandmothers for Peace/Northland Chapter, Superior, WI
Indigenous Law Students Association, Madison, WI
Lakes and Prairies Life Community, Ferryville, WI
Mining Impact Coalition of Wisconsin, Madison, Wisconsin
Nukewatch, Luck, Wisconsin
RENEW Wisconsin, Madison, Wisconsin
Student Environmental Action Coalition, U. of Wisconsin, Milwaukee
University of Wisconsin Greens, Madison, WI
Watershed Information & News Service, Shawano, WI
West Allis Community Media Center, West Allis, WI
Wisconsin Green Party, Sun Prairie, Wisconsin

Powder River Basin Resource Council, Douglas, Wyoming
Wyoming Outdoor Council, Lander, Wyoming
Wyoming Peace Initiatives, Cheyenne, WY

Supporting documentation:

Great Lakes United, 20 th Annual General Meeting, Yucca Mountain Resolution, June 9, 2002, Chicago, IL.

Michigan Environmental Council, Policy on High Level Radioactive Waste, ADOPTED: May 22, 2002, Lansing, MI.

May 13, 2002 press release, “Citizens Groups Charge Nuclear Industry Has Overbearing Influence on Congress’s Yucca Mountain Nuclear Waste Dump Decision,” Lansing, Michigan.

May 7, 2002 “Statement by Jill Lancelot, Legislative Director at Taxpayers for Common Sense for the May 7 th Yucca Mountain Press Conference,” Washington D.C.

May 7, 2002 press conference opposing Yucca Mountain prior to the US House of Representatives vote to override the Gov. of Nevada’s veto, Washington, DC.

May 6, 2002 press release, “INDIAN POINT SAFE ENERGY COALITION URGES CONGRESSIONAL REPRESENTATIVES TO OPPOSE YUCCA MOUNTAIN RADIOACTIVE WASTE DUMP,” New York.

May 2, 2002 League of Women Voters of the US email urgent lobby request, “LEAGUE OPPOSES YUCCA MOUNTAIN AS AN UNSAFE REPOSITORY FOR NUCLEAR WASTE.”

April 16, 2002 Participants in National Environmental Rally/Lobby Day at US Capitol against Nuclear Waste Transport to Yucca Mountain, Washington, D.C.

March 26, 2002 letter to the U.S. Senate from major national environmental, consumer and safe energy organizations urging Senators to uphold Nevada’s veto of DOE’s “premature and technically unfounded recommendation in favor of the Yucca Mountain site.”

January 29, 2002 letter to the U.S. Congress about the DOE Inspector General report on alleged conflict of interest involving the Yucca Mountain Project’s law firm, Winston and Strawn.

March 12, 2001 letter to President George W. Bush re: impending Environmental Protection Agency promulgation of radiation release regulations for Yucca Mountain.

December 14, 2000 letter to Energy Secretary Richardson regarding alleged bias by DOE Yucca Mountain Project contractor TRW, Inc. in the preparation of the “Yucca Mountain Site Recommendation Considerations Report”.

May 1, 2000 letter to U.S. Senators urging them to sustain President Clinton’s veto of S. 1287.

2000, 66 th UE Convention, Resolution: “Keep Highly Radioactive Nuclear Waste Off Our Highways And Railroads,” http://www.ranknfile-ue.org/policy_rw.html

Policy Statement Adopted by the Governing Council of the American Public Health Association on November 10, 1999, as reported in American Journal of Public Health, March 2000, Vol. 90, No. 3, page 461: “Declare Proposed National Permanent Nuclear Waste Repository Site Unsafe…”.

December 12, 1998 “Petition to the Secretary of Energy for Disqualification of Yucca Mountain from Consideration as a Nuclear Waste Repository”.

List of 129 environmental, religious, and citizen organizations against S. 104 (2/13/97).

Letters to US Senators and Representatives on HR 1020, January 8, 1997.

April 16, 1996 Letter to Hon. Robert Dole, Majority Leader, United States Senate.

Letter to Speaker of the House Newt Gingrich and US Representatives on HR 1020, November 8, 1995.

Copies of these and additional supporting documents are available upon request.

Revised May 19, 2002, by Kevin Kamps, Nuclear Information & Resource Service