Tell the NRC "Don't Screw Nevada!" Submit Your Comments on NRC Proposed Repository Licensing Rule for Yucca Mountain by June 30th
The deadline for written comments on the NRC's Proposed Repository Licensing Rule for Yucca Mountain is quickly approaching. There is only one week left --comments are due on or before Wednesday, June 30, 1999!
Comments are critical at this time. The NRC's Proposed Rule would weaken radiation protection standards for the public and the environment by
usurping EPA's legally mandated jurisdiction (under the Energy Policy Act of 1992) to set the standards for the proposed Yucca Mountain repository. This would accommodate the DOE, which, in its impatience to
move towards its recommendation to the President and its license application for the Yucca Mountain repository, is pressuring NRC to set standards soon, in advance of the EPA. This would also serve to lower the standards to such an extent that Yucca Mountain might still qualify to serve as the repository for the nation's high-level radioactive waste, despite Yucca Mountain's severe safety shortcomings. The NRC's
proposed rule should be withdrawn until EPA promulgates standards, at which time NRC can then modify its repository licensing rule to meet the
EPA standards, as required by law.
In order to make a bigger "splash" with the NRC, we are encouraging individuals and organizations to submit their own comments, rather than to simply sign on to NIRS' comments. This way, NRC will have to handle each individual entry as one more distinct public comment; the larger the number of such comments, the more clear it will be that citizens across the USA are concerned with the NRC and DOE forcing shortcuts on safety at Yucca Mountain.
The full text for the NRC proposed rule can be found in the 2/22/99 Federal Register (Vol. 64, Num. 34, starting at page 8639 -- the document is 78 pages long), which is accessible via internet at http://www.access.gpo.gov/su_docs/aces/aces140.html
This is the Federal Register Online via GPO Access. Click on the "Federal Register" button. Make sure the date is set for 1999, and on 2/22/99. Use "nuclear" as the search term, and click "submit". If you have problems, phone Kevin Kamps at NIRS (ph. 202-328-0002), or the GPO
Access User Support Team (ph. 202-512-1530)
NIRS will post its comments on the NIRS website (www.nirs.org) on Monday afternoon, June 28th. Please feel free at that time to "borrow" ideas, to formulate comments in your own words.
In the meantime, the following points give an overview about why NRC's proposed rule is unacceptable from environmental, public health, and legal perspectives:
* NRC has no legal authority to usurp EPA's legally mandated jurisdiction, under the Energy Policy Act of 1992, to set radiation release, public health, and environmental protection standards for the proposed Yucca Mountain repository.
As mentioned above, the NRC's proposed rule should be withdrawn, until EPA promulgates standards, at which time NRC can then modify its repository licensing rule to meet the EPA standards, as required by law.
* Why should Nevadans living near the proposed Yucca Mountain repository be less protected from radioactive contamination of their water supply than, say, New Mexicans living near WIPP? The NRC rule proposes a lesser standard of protection for Yucca Mountain releases, despite the fact that local Nevadans will also be exposed to radioactivity from two other sources: the Nevada Test Site, and the Beatty "low level" radioactive waste dump. Since groundwater contamination would deliver Yucca's worst doses of radioactivity to nearby residents, water quality must be protected to the fullest extent of the law, which this proposed NRC rule fails to do. Yucca Mountain should have the most stringent of standards, for leakage will only increase over time. Such stringent standards would guard against an unsafe location being licensed for the repository.
* This NRC proposed rule does not assure adequate protection for future generations of people who would be exposed to radionuclide releases from the proposed Yucca Mountain repository.
* The proposed rule does not limit the thermal energy output of high-level radioactive waste per unit area of the repository emplacement area, which is a critical design and safety shortcoming. Yucca Mountain's rock may not be capable of containing such high levels of thermal heat and radioactivity.
* Lots can change in 10,000 years. Due to the tremendous uncertainty associated with the proposed Yucca Mountain repository, radiation protection standards for the public health and the environment should be more stringent, rather than the less stringent standards NRC puts forth in this proposed rule.
* This NRC proposed rule seriously underestimates the potential dangers associated with future, unpredictable human intrusions over the next several centuries or millennia which could breach the proposed repository at Yucca Mountain.
* Despite the complexity and decades-long process involved with the Yucca Mountain repository proposal, this NRC rule would weaken or undo the requirement that DOE systematically record its decisions that significantly concern safety, how those decisions were made, and what factors influenced them.
Given the grave consequences of radiation leakage from a repository, systematic accountability on scientific and engineering decisions related to safety must be upheld.
Comments should be mailed to:
Secretary U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001 attn. Rulemakings and Adjudications Staff
Comments can also be submitted via the NRC's interactive rulemaking website, through the NRC home page. It allows you to submit a word processing file containing your comments. Go to http://www.nrc.org, and click on Rulemaking at the bottom of the page. Click on the following sequence of choices: Rulemaking Forum; News, Information, and Contacts for Current Rulemakings; Proposed Rulemaking -- Disposal of High-Level Radioactive Wastes in a Proposed Geologic Repository at Yucca Mountain, Nevada; Public Comments; Submit a Document. You then fill in the blanks (name, address, etc.), load your file, and send it.
Your comments can also be faxed to the Office of the Secretary at (301) 415-1101 (put to the attention of Andrea Byrd). Comments can be e-mailed, as well, to CAG@nrc.gov
Please include "RE: Proposed Rule : Disposal of High-Level Radioactive Wastes in a Proposed Geologic Repository at Yucca Mountain, Nevada" at the top of your comments.
If you have questions about any of these ways to submit your comments, contact Kevin Kamps at NIRS (ph. 202-328-0002), or Carol Gallagher at NRC (ph. 301-415-5905).
Thank you for any action you can take on this important matter. Please contact Kevin Kamps at NIRS if you have any questions: ph. 202-328-0002.
This !QU! was prepared by Kevin Kamps, NIRS Nuclear Waste Specialist, on Wednesday, June 23, 1999.
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