In cooperation with Citizen Alert and Washington DC based groups, HOME drafted the following letter. It was signed by 103 international organizations and individuals, including Las Vegas Mayor Oscar Goodman and Bonnie Raitt.
December 14, 2000
The Honorable Bill Richardson
Secretary of Energy
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585
Dear Secretary Richardson,
The undersigned public interest and environmental organizations, on behalf of our combined memberships, wish to express our deep concerns about the recent revelations involving the Yucca Mountain Project. The Las Vegas Sun newspaper reported on December 1st that Ivan Itkin, the Department of Energy (DOE) Office of Civilian Radioactive Waste Management’s director, acknowledged he is close to recommending Yucca Mountain as a safe site for the permanent national repository for high-level nuclear waste. "We do not see any showstoppers," Itkin is quoted as saying. The article also reported that a draft copy of an overview of the soon to be released Yucca Mountain "Site Recommendation Considerations Report" (SRCR) obtained by the Las Vegas Sun states:
"The report concludes that a repository that is likely to meet the safety standards proposed by the Environmental Protection Agency and the licensing requirements of the Nuclear Regulatory Commission can be designed, constructed and operated at the Yucca Mountain site." It is very troubling that Dr. Itkin and the SRCR are making such confident assertions, when EPA standards and NRC requirements have not yet even been finalized.
In November 1998, over 200 public interest and environmental organizations petitioned you to disqualify Yucca Mountain from any further consideration as a potential nuclear waste repository. The request was based on the DOE’s own Guidelines for Site Suitability. Less than 50 year old rainwater found by DOE scientists at the proposed repository depth within Yucca Mountain provides compelling evidence that "pre-waste-emplacement ground-water travel time from the disturbed zone to the accessible environment is expected to be less than 1,000 years" along a pathway of likely and significant radionuclide travel. Thus, under 10 Code of Federal Regulations Part 960.4-2-1, "Post-Closure Disqualifying Condition for Hydrology," the Yucca Mountain site should be disqualified. The Nuclear Waste Policy Act gives the Secretary of Energy clear authority to terminate site characterization at Yucca Mountain at any time that the site is determined to be unsuitable.
Your Department responded to the petition not by challenging the assertion that the Yucca Mountain site should be disqualified, but rather by stating that DOE simply needed more time to study the site.
However, just one year later, in November, 1999, DOE proposed to change 10 CFR 960’s Guidelines for Site Suitability by simply eliminating individual disqualifying conditions, such as the one for fast flow of water cited in the petition. Rather than answer the charge in the petition, DOE decided to change the rules in the middle of the game. Yet again, well over 150 public interest and environmental organizations protested DOE’s actions via the public comment process, and also wrote you to urge that the proposed rule change be withdrawn. There has been no official response, but DOE has moved ahead in its Yucca Mountain Project activities behaving as if the proposed change is already a finalized rule.
DOE’s ever more apparent disregard for the concerns of the public interest and environmental community came into sharp focus in light of the contents of a two page DOE contractor memo attached to the SRCR draft overview obtained by the Las Vegas Sun. The memo states "The Overview provides information that potential supporters can use in expressing support for a site recommendation. It is not intended to convert those who oppose a Yucca Mountain repository or any solution to the nuclear waste problem." It goes on to state "the technical suitability of the site is less of a concern to Congress than the broader issue of whether the nuclear waste problem can be solved at an affordable price in both financial and political terms."
Such statements represent an outrageous betrayal of the public trust.
The DOE is supposed to serve the American people, not the nuclear power industry. It is now all too clear that DOE’s impending determination that Yucca Mountain is a suitable site for a nuclear waste repository is based not on sound science and public safety, but on politics and money.
Many of our organizations have faithfully taken part-every step of the way and over the course of many years—in DOE’s official public participation process for the Yucca Mountain Project. We have urged you, Secretary Richardson, to disqualify the site for safety reasons. We have urged you and your Department to enforce DOE’s own safety-based siting guidelines, not to do away with them. We have continuously raised questions about the site’s safety, or lack thereof. DOE has proven itself disingenuous. It is abundantly clear that the soon to be released DOE Site Recommendation Considerations Report for Yucca Mountain is a document intended not to address issues of public health, safety, and the environment, but rather to help nuclear industry lobbyists "sell" Yucca Mountain on Capitol Hill.
Upon release of the SRCR, DOE will yet again ask the public and our organizations to take part in hearings. But DOE seems much more concerned with what’s happening in nuclear utility corporate boardrooms and the halls of power than in public hearings. These recent revelations of DOE collusion with the nuclear industry, placing money and politics over public involvement, safety, and sound science, have hammered the final nails in the coffin of the Yucca Mountain Project’s credibility. Given the damage, it is hard to say what, if anything, DOE could do to restore faith in its activities at Yucca Mountain.
For the reasons cited above, we urge you to exercise your clear authority under the Nuclear Waste Policy Act to disqualify the Yucca Mountain site based on its unsuitability. As a first step toward this end, DOE should withdraw its fatally flawed Draft Environmental Impact Statement. A legitimate Environmental Impact Statement would adequately address groundwater travel time, site specific transportation impacts in the 43 States that would be traversed by tens of thousands of high-level nuclear waste truck and train shipments, and the cataclysmic risks of earthquakes, volcanic eruptions, and the upwelling of superheated water that could flood the repository within Yucca Mountain, releasing massive amounts of radiation into the environment. A legitimate Environmental Impact Statement would serve as the basis for the Energy Secretary’s decision to disqualify Yucca Mountain.
High-level radioactive wastes are among the deadliest poisons on Earth, and remain hazardous for hundreds of thousands of years. Nuclear waste isolation from the living environment is the goal of the nuclear waste repository program. No compromise is acceptable. An unsuitable site should not be used for high-level nuclear waste disposal. If Yucca Mountain cannot meet stringent safety standards, it must be disqualified. We await your action.
Respectfully Submitted,
Michael Mariotte, Executive Director, Nuclear Information and Resource Service, Washington, DC
Wenonah Hauter, Director, Public Citizen’s Critical Mass Energy & Environment Program, Washington, DC
Jennifer Olaranna Viereck, Director, HOME: Healing Ourselves & Mother Earth, Tecopa CA
Kaitlin Backlund, Executive Director, Citizen Alert, Reno, NV
Kalynda Tilges, Citizen Alert, Las Vegas, NV
Scott Denman, Executive Director, Safe Energy Communication Council, Washington, DC
Mayor Oscar Goodman, City of Las Vegas, Nevada
Bonnie Raitt, c/o Kathy Kane, ARIA Foundation, Los Angeles, CA
Michael J Keegan, Coalition for a Nuclear Free Great Lakes, Monroe, MI
Corrine Carey, Don’t Waste Michigan, Grand Rapids, MI
Keith Gunter, Citizens’ Resistance at Fermi Two, Monroe, MI
Judi Friedman, PACE, INC. (People’s Action for Clean Energy, Inc.), Canton, CT
Earl Hicks, Grassroots Greywater, Ithaca, NY
Jack and Felice Cohen-Joppa, the Nuclear Resister, Tucson AZ
Debby Katz, Citizens Awareness Network, Shelburne Falls, MA
The ZHABA Collective, Amsterdam, The Netherlands
Sal Mangiagli, Board Member, Citizens Awareness Network, CT chapter, Haddam CT.
Anthony Guarisco, Director, The Alliance of Atomic Veterans, Topock Arizona
Jonathan Mark, Post Cassini Flyby News, Wendell Depot, MA
Iowa City/Johnson County Green Party
Holly Hart, Secretary, Iowa Green Party
E.M.T. O’Nan, Director, Protect All Children’s Environment, Marion, North Carolina
Nancy Burton, Connecticut Coalition Against Millstone, Mystic CT
George Crocker, Executive Director, North American Water Office, Lake Elmo MN
Bruce A Drew, Steering Committee, Prairie Island Coalition, Minneapolis MN
Bradley Angel, Greenaction for Health and Environmental Justice, San Francisco, CA
Barbara Hickernell, Alliance to Close Indian Point, Ossining, New York
Ellen Thomas, Proposition One Committee, Washington DC
Michael Welch, office coordinator, Redwood Alliance & REEI, Arcata, CA
Bill Smirnow, Nuclear Free New York, Huntington, New York
Kevin Petajan, West Allis Community Media Center, West Allis, WI
Bernice Kring, Citizens Along the Roads and Tracks (CART), Sacramento, CA
Bob Darby, Food Not Bombs, Atlanta GA
Dave Rapaport, Executive Director, Vermont Public Interest Research Group, Montpelier, VT
Alice Slater, GRACE Global Resource Action Center for the Environment, New York, NY
Coleman Smith, President, Citizens Environmental Defense League, Bowling Green, Kentucky
Chris Williams, Ex. Dir., Citizens Action Coalition of Indiana, Indianapolis, IN
Janet Marsh Zeller, Executive Director, Blue Ridge Environmental Defense League, Glendale Springs, NC
Cheryl Becker, Body Wisdom Incorporated, Lake Bluff, IL
B.J. Medley, Earth Concerns of Oklahoma, Tulsa, Ok
Adrian F.Drake, Group for the South Fork, Bridgehampton ,NY
Chuck Johnson, Center for Energy Research, Portland, Oregon
Lewis Seiler,President, V.O.T.E. Action Committee
Dan Hamburg, Executive Director, Voice of the Environment
John Runkle, Conservation Council of NC, Raleigh, NC
Kate Donnelly and Clay Colt, Donnelly/Colt, Hampton, CT
Charlie Hilfenhaus, Alliance of Atomic Veterans Atomic Workers Div., Las Vegas, NV
Loren Olson, Community Times, West Lafayette, IN
Eleanor Rosalini, Tippicanoe Environmental Council, West Lafayette, IN
Marc P. B. Page, Nevada Desert Experience, Las Vegas NV
Kyle Rabin, Environmental Advocates, Albany, NY
Don Hancock, Southwest Information and Research Center, Albuquerque, NM
Paloma Galindo, Oak Ridge Environmental Peace Alliance, Oak Ridge, TN
Jim Warren, NC WARN (Waste Awareness and Reduction Network), Durham, NC
Grace Marie Potorti, Rural Alliance for Military Accountability (RAMA), Reno, NV
Mike Ewall, Pennsylvania Environmental Network, Philadelphia, PA
Traci Confer, Activists' Center for Training In Organizing and Networking (ACTION), Philadelphia, PA
Bonnie Urfer and John LaForge, Nukewatch, Luck, WI
Harry Rogers, Carolina Peace Resource Center, Columbia SC
Robert Musil, Physicians for Social Responsibility, Washington, D.C.
Susan Gordon, Alliance for Nuclear Accountability, Seattle, WA
Gary Richardson and Beatrice Brailsford, Snake River Alliance, Pocatello, Idaho
Susan Perry Luxton, Citizens Regulatory Commission, Waterford, CT
Dave Kraft, Nuclear Energy Information Service, Evanston, IL
Cheryl Lau, Citizens Against Nuclear Waste in Nevada (CANWIN), Carson City, NV
Sally Light, Nevada Desert Experience, Oakland, CA
Kimberly Robson, Women's Action for New Directions (WAND), Washington, D.C.
State Representative Nan Grogan Orrock (GA), Women Legislators' Lobby (WiLL), Washington, D.C.
Judy Treichel, Nevada Nuclear Waste Task Force, Las Vegas, NV
Corbin Harney, Shundahai Network, Pahrump, NV
Brent Wilkes, League of United Latin American Citizens, Washington, DC
Bea Covington, Missouri Coalition for the Environment, St. Louis, MO
Damon Moglen, Greenpeace International, Washington DC
LeRoy Moore, Rocky Mountain Peace and Justice Center, Boulder, CO
Cynthia of the Desert, Utah Peace Test, Salt Lake City, UT
Margaret Laybourn, Wyoming Peace Initiatives, Cheyenne, WY
Terry Lodge, Toledo Safe Energy Coalition, Toledo, OH
Greg Wingard, Waste Action Project, Seattle, WA
Mary Byrd Davis, Yggdrasil Institute, Georgetown, KY
Scott Cullen and Pamela Slater, STAR (Standing for Truth About Radiation), East Hampton, NY
Sidney J. Goodman, P.E., SJG Design, Inc., Paramus, NJ
David Albano, Green Party of the Lower Hudson Valley, New York, NY
David Swain, Haywood Peace Fellowship, Waynesville, NC
Michael W. Stowell, Nuclear Weapons Free Zone Commission, Arcata, California
Cris Gutierrez, Southern California Abolition 2000, Santa Monica, CA
Pamela A. Jordan, NGO Committee on Disarmament, New York, NY
Alan Muller, Green Delaware, Port Penn, DE
Steve Jambeck/Joan Flynn, EnviroVideo, Tilden, NY
Leslie Minerd, Hip-Wa-Zee, Columbia, SC
Grace de Haro, Lihue Association, Bariloche, Rio Negro, Argentina
Junko Abe, Good Bye Nukes
Ehime Network, Matsuyama, Japan
Paul Brown, PLAN Progressive Leadership Alliance of Nevada, Las Vegas, NV
Toyabi Chapter of Sierra Club, Las Vegas, NV
Tom Goldtooth, Indigenous Environmental Network (IEN), Bemidji, MN
Jean Clauitaire-Frerreys Pouele, Ex. Dir. Earth Action- Congo, Brazzaville, Republique Du Congo
cc:
Council on Environmental Quality, Linda Lance
Environmental Protection Agency, Carol Browner
DOE Office of Civilian Radioactive Waste Management, Ivan Itkin
Office of Management and Budget
United States Senators
United States Representatives