[NukeNet] Oppose Yucca Mtn. rad. waste dump: DOE comments due

[Kevin Kamps]

Beyond Nuclear
Action Alert

Jan. 8, 2008

Comments on EIS Documents Due to DOE by January 10
re: Dangerous Yucca Mountain High-Level Radioactive Waste Dump Proposal

Beyond
Nuclear will submit the following ten points to the U.S. Department of
Energy in opposition to the proposed Yucca Mountain atomic waste dump
on Jan. 10, the deadline for public comments on DOE's latest iteration
of its endlessly changing "evolving and flexible" (that is, half-baked)
dumpsite and waste transport plans.

Please
either sign your organization onto Beyond Nuclear's submission by
sending your name, your title, your group name, city, and state to
Kevin Kamps at [mailto:kevin at beyondnuclear.org] kevin at beyondnuclear.org
ASAP (by close of business on Jan. 10 at the latest), or else use the
points below to prepare your own comments. Be sure to submit them on or
before Jan. 10, by sending them to:

DOE's online comment form at
[http://www.ymp.gov/ym_repository/seis/comment_seis.shtml] http://www.ymp.gov/ym_repository/seis/comment_seis.shtml

Or to DOE's email address at [mailto:EIS_Office at ymp.gov] EIS_Office at ymp.gov

Or by fax to 1-800-967-0739

Or by mail to 
EIS
Office, U.S. Department of Energy, Office of Civilian Radioactive Waste
Management, 1551 Hillshire Drive, Las Vegas, NV 89134.

Be
sure to put "Draft Repository SEIS, Draft Nevada Rail Corridor SEIS,
and Draft Rail Alignment EIS" as a label to clearly identify which
documents you are commenting on.

Thanks for taking action against the dangerous Yucca Mountain radioactive waste dump proposal!

No Nukes!

Kevin Kamps
Radioactive Waste Watchdog
Beyond Nuclear
6930 Carroll Avenue, Suite 400
Takoma Park, Maryland 20912
(301) 270-2209
Fax (301) 270-4000
[mailto:kevin at beyondnuclear.org] kevin at beyondnuclear.org
[http://www.beyondnuclear.org/] www.beyondnuclear.org



Beyond Nuclear's comments to DOE 
re: the Draft Repository SEIS, Draft Nevada Rail Corridor SEIS, and Draft Rail Alignment EIS

1. DOE should extend the public comment period by 60 additional
days, given that these environmental impact documents are a foot thick
altogether. The public needs additional time to digest the proposals,
analyses, and references, and to compare and contrast them with the
three foot thick "Final" (guess it wasn't final, actually!) EIS
published by DOE in 2002, in order to give meaningful comments.

2. Shipping tens of thousands of high-level radioactive waste
trucks, trains, and barges through 45 states and the District of
Columbia risks severe accidents and terrorist attacks. This could
release catastrophic amounts of deadly radioactivity in major
population centers. These waste transports would represent potential
Mobile Chernobyls and dirty bombs on wheels rolling past the homes of
millions of Americans. Each truck cask of irradiated nuclear fuel would
contain 350,000 curies of radioactive cesium and strontium, or about 20
to 30 times the amount of these harmful fission products released by
the Hiroshima atomic bomb. Every dedicated train hauling three or four
rail casks would contain more radioactive cesium-137 than the total
amount released during the Chernobyl nuclear catastrophe. DOE must
integrate into its Yucca Mountain transport analysis its own proposals,
under the Bush administration's "Global Nuclear Energy Partnership"
(GNEP), for waste imports from overseas, and waste shipments to
reprocessing (plutonium extraction) centers in the U.S. before waste
shipments to Yucca for final disposal. DOE must also analyze the
increased transport risks from its proposal to nearly double the amount
of waste to be buried at Yucca to 130,000 metric tons – which on its
face violates the Nuclear Waste Policy Act, as amended, which limits
the amount of waste that could be buried at the first repository to
70,000 metric tons, at least until a second repository is opened in
another state.

3. DOE proposed the equivalent of the TAD (Transport, Aging, and
Disposal) canisters in the early to mid-1990s, only back then it was
called MPC (multi-purpose canisters). DOE needs to completely explain
why it is attempting to revive an idea it had dismissed as unworkable
over a decade ago. DOE needs to fully explain the increased risks to
workers and the public at and near the nuclear reactors across the U.S.
where TADs would be loaded and permanently sealed forevermore. Those
risks have now been shifted largely to the reactor sites, away from
Yucca where they were previously proposed to take place. How will waste
handling errors at reactors, especially involving defective TADs and
damaged irradiated nuclear fuel, worsen transport risks, as well as
radioactivity releases at Yucca over time? DOE must also explain the
disconnect between its GNEP proposal to reprocess wastes, and its
current Yucca proposal to permanently seal shut wastes at reactors in
TAD containers.

4. How can DOE propose "aging pads" at Yucca Mountain, when the
Nuclear Waste Policy Act, as amended, prohibits an interim monitored
retrievable storage site co-located in the same state as the
repository? DOE's proposal is actually illegal, in that it attempts to
place all of the burdens (both interim storage and permanent disposal)
on one state. DOE needs to fully analyze the earthquake risks at its
proposed interim storage site at Yucca, especially considering the
earthquake fault line recently discovered directly under DOE's original
"aging" pad location.

5. DOE has selected four companies to design the TAD canisters,
including Holtec International. But a whistleblower from the largest
U.S. nuclear utility has alleged and extensively documented since 2000
that Holtec's waste storage/transport containers seriously violate
federal quality assurance (QA) regulations. This calls into question
the containers' structural integrity, especially under transport
accident conditions. This industry whistleblower is entirely backed up
by a retired U.S. Nuclear Regulatory Commission safety engineer and dry
cask storage expert. How can DOE give such a contract to a company that
so violates QA, especially after DOE's own extensive QA violations at
the Yucca Mountain Project?

6. All of the land at the Yucca Mountain dump project is within the
treaty lands of the Western Shoshone Indian Nation, as affirmed by the
"Peace and Friendship" Treaty of Ruby Valley, signed by the U.S.
government in 1863. Treaties are declared by the U.S. Constitution to
be the supreme law of the land, equal in stature to the Constitution
itself. As the Western Shoshone Nation opposes radioactive waste
dumping at its sacred Yucca Mountain, where traditional ceremonies have
continued to be conducted right up to recent years, DOE should
terminate the Yucca Mountain Project for this reason alone. The United
Nations Committee on the Elimination of Racial Discrimination ruled in
recent years that the Yucca Mountain Project represents a human rights
violation against the indigenous Western Shoshone Nation, and has urged
the U.S. government to cease and desist its activities there. The Yucca
Mountain dump proposal represents blatant environmental racism, as
stated by Ian Zabarte of the Western Shoshone National Council at DOE's
recent Las Vegas and Washington, D.C. hearings.

7. A federal judge, ruling against DOE and in favor of the State of
Nevada over DOE's illegal use of water at the Yucca Mountain Project,
recently concluded that DOE either is engaging in "busy work" at the
site (wasting not only water, but also Nuclear Waste Fund monies), or
else it misled Congress and the President in 2002 that site
characterization had concluded at the site when DOE announced the site
suitable for a high-level radioactive waste dump. The Nuclear Waste
Policy Act, as amended, required DOE to apply for its license
application on Oct. 23, 2002, assuming that DOE's site suitability
determination would mean that DOE must be extremely close to ready to
submit a complete license application. Yet, incredibly, over five years
later, DOE has still not submitted its license application. DOE has
known for over a decade that rainwater percolates relatively quickly
through the proposed burial site, and risks fast corrosion of the waste
containers that would be buried there. In fact, DOE scandalously did
away with its own Site Suitability Guidelines that would have
disqualified the site for this reason from any further consideration,
just before declaring the site suitable. DOE should admit to Congress
and the President that the site is in fact not suitable, and begin to
conduct a sound scientific search for suitable geology that can isolate
radioactive waste from the living environment for a million years. DOE
must stop its attempt to rush the submission of its still half-baked
licensing application by its arbitrary, capricious, self-imposed June
30, 2008 deadline. This is an obvious attempt to initiate the Yucca
licensing proceeding before the pro-Yucca dump Bush administration
leaves office, to make Yucca a "done deal" before the next (and
possibly anti-Yucca dump) President enters the White House.

8. The National Academy of Science reported recently, in its Seventh
Biological Effects of Ionizing Radiation (BEIR) report, that any dose
of radiation, no matter how small, carries a health risk, and that in
fact those risks at low doses are disproportionately high,
significantly higher than previously reported. DOE has engaged with the
U.S. Environmental Protection Agency and the Nuclear Regulatory
Commission, in secretive behind closed door meetings, to play a game of
"hide the ball" from the public. All agencies, including DOE, must stop
using statistical manipulations to hide the actual levels of radiation
dose exposure and consequent health impacts that vulnerable individuals
and populations downstream and downwind of the proposed Yucca Mountain
dump would suffer over the next million years. DOE should stop using
"Standard or Reference Man" (analyzing radiation dose health impacts on
a young, healthy adult white male) and instead use "Standard or
Reference Pregnant Woman." DOE should analyze the health impacts of
Yucca's radioactive waste leakage into the drinking water supply below
on the most vulnerable individuals and populations downstream,
including pregnant women, fetuses, infants, children, the elderly,
others with compromised immune systems, as well as Western Shoshone
Indians living traditional lifestyles and subsistence farmers living
downstream in the future, and persons consuming foodstuffs (such as
dairy products) grown nearby Yucca but exported elsewhere.

9. DOE should much more thoroughly analyze the negative impact on
property values along all road, rail, and waterway routes across the
continental United States that would be used to ship wastes to Yucca.
Courts, juries, and socio-economic studies have found that property
values decrease significantly near declared radioactive waste transport
routes. DOE must identify in detail all routes it plans to use for
shipping wastes to Yucca before proceeding any further with its attempt
to obtain a license to build and operate the dump, and should hold
hearings in every state thus impacted.

10. Nearly 1,000 environmental, public interest, consumer, and
taxpayer organizations, as well as many cities, counties and even
states -- representing many millions of Americans -- have expressed
opposition to various aspects of the Yucca Mountain dump proposal over
the past twenty years. DOE should declare the Yucca Mountain site
unsuitable, terminate the project, return the land to its prior
condition, and seek guidance from Congress and the President on next
steps for addressing the nuclear waste dilemma, as provided for in the
Nuclear Waste Policy Act, as amended. DOE should heed the call by 150+
groups across the U.S., that high-level radioactive wastes stored
on-site at reactors be safeguarded and secured against accidents,
attacks, and leakage until a scientifically sound and socially
acceptable long term waste management plan is arrived at through
democratic and just means. The one to two million dollars per day being
wasted at the dead end Yucca Mountain Project should be immediately
re-directed to securing and safeguarding on-site waste storage at
reactors, that will inevitably remain in place for decades to come.
Submitted to DOE on Jan. 10, 2008 by

Kevin Kamps
Radioactive Waste Watchdog
					

Beyond Nuclear at NPRI
6930 Carroll Avenue, Suite 400
Takoma Park, MD 20912
Tel: 301.270.2209  Fax: 301.270.4000
Email: [mailto:info at beyondnuclear.org] info at beyondnuclear.org
Web: [http://www.beyondnuclear.org//] www.beyondnuclear.org


 



					
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Kevin Kamps
Radioactive Waste Watchdog
Beyond Nuclear
6930 Carroll Avenue, Suite 400
Takoma Park, Maryland 20912

Office phone: (301) 270-2209
Cell phone: (240) 462-3216
Fax: (301) 270-4000
kevin at beyondnuclear.org
www.beyondnuclear.org
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