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. 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's failure to remain impartial and the agency's willingness to place 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
Dan Becker
Sierra Club
Washington, DC
Anna Aurilio
U.S. PIRG
Washington, DC
Courtney Cuff
Friends of the Earth
Washington, DC
Damon Moglen
Greenpeace International
Washington, DC
Scott Denman
Executive Director
Safe Energy Communication Council
Washington, DC
Susan Gordon
Director
Alliance for Nuclear Accountability
Seattle, WA
Robert Musil, PhD
Physicians for Social Responsibility
Washington, D.C.
Brent Wilkes
National Executive Director
League of United Latin American Citizens
2000 L Street, NW, Suite 610
Washington, DC 20036
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.
Tom Goldtooth
Indigenous Environmental Network (IEN)
Bemidji, MN
Phyllis S. Yingling
Chair, US Section,
Women's International League for Peace and Freedom.
1213 Race St.
Philadelphia, PA 19107
John Bailey
Institute for Local Self Reliance
1313 Fifth St. SE
Minneapolis, MN 55414
Paul Brown
PLAN, Progressive Leadership Alliance of Nevada
Las Vegas, NV
Mayor Oscar Goodman
City of Las Vegas
Winona LaDuke
Honor the Earth
Minneapolis, MN
David Krieger
President, Nuclear Age Peace Foundation
Santa Barbara, CA
Don Hancock
Southwest Information and Research Center
Albuquerque, NM
Michael J Keegan
Coalition for a Nuclear Free Great Lakes
P.O. Box 331
Monroe, MI 48161
Corrine Carey
Don't Waste Michigan
Grand Rapids, MI
Keith Gunter
Citizens' Resistance at Fermi Two
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Judi Friedman
PACE, INC. (People's Action for Clean Energy, Inc.)
Canton, CT
Earl Hicks
Grassroots Greywater
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Ithaca, NY 14850
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The Nuclear Resister
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Citizens Awareness Network
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HOME: Healing Ourselves & Mother Earth
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Haddam, CT.
Anthony Guarisco
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The Alliance of Atomic Veterans
Topock, AZ
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Post Cassini Flyby News
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Holly Hart
Secretary, Iowa Green Party
Iowa City/Johnson County Green Party
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Director
Protect All Children's Environment
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Connecticut Coalition Against Millstone
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North American Water Office
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Greenaction for Health and Environmental Justice
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Alliance to Close Indian Point
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Proposition One Committee
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Redwood Alliance & REEI
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Nuclear Free New York
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Kevin Petajan
West Allis Community Media Center
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Food Not Bombs
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Global Resource Action Center for the Environment (GRACE)
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Citizens Environmental Defense League
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Citizens Action Coalition of Indiana
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Blue Ridge Environmental Defense League
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Body Wisdom Incorporated
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Earth Concerns of Ok
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Group for the South Fork
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Bridgehampton, NY 11932
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Center for Energy Research
Portland, OR
Lewis Seiler
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V.O.T.E. Action Committee
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Voice of the Environment
John Runkle
Conservation Council of NC
Raleigh, NC
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Donnelly/Colt
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Grandmothers for Peace International
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F.A.C.T.S. (For A Clean Tonawanda Site), Inc.
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The Southwind Group
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Three Mile Island Alert
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Southwest Workers Union
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Americans for Democratic Action
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The Atomic Mirror
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Nuclear Energy Information Service
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Virginia Tech
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Mississippi Corridor Neighborhood Coalition
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Women's International League for Peace and Freedom
U.N. Office
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Tri-Valley CAREs
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Pennsylvania Environmental Network
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Activists' Center for Training In Organizing and Networking (ACTION)
Philadelphia, PA
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Nukewatch
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Columbia SC
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Beco, Inc.
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East Bay Peace Action
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University of Delaware
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Utah Peace Test
Salt Lake City, UT
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Director
Bison Land Resource Center
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Green Party
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GANE - Georgians Against Nuclear Energy
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Jersey Shore Nuclear Watch
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Mangrove Action Project
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Sunrise Alternatives
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Cannon Falls, MN
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The Nuclear Democracy Network
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Connecticut Opposed to Waste
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Alliance of Atomic Veterans
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Center for Safe Energy
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Shundahai Network
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SERV
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Nuclear Guardianship Project
Berkeley, CA
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GE Stockholders' Alliance
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Katharine Dodge
Energy Chair
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Snake River Alliance
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Kathleen Sullivan, PhD
Project Edna (engaged democracy for the nuclear age)
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Chenango North Energy Awareness Group
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Nevada Desert Experience
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Community Times
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Tippecanoe Environmental Council
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Citizens Regulatory Commission
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Radiological Evaluation and Action Project, Great Lakes (REAP, GL)
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Waste Action Project
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Yggdrasil Institute
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SJG Design, Inc.
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Green Party of the Lower Hudson Valley
NY
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Haywood Peace Fellowship
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Southern California Abolition 2000
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Wyoming Peace Initiatives
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Families Against Incinerator Risk (FAIR)
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Friends of Nevada Wilderness
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Citizen Power
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West Michigan Environmental Action Council
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Don't Waste Arizona, Inc.
Phoenix, AZ
OUr Earth
University of Oklahoma
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Norman, OK 73019
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University of Oklahoma
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Environmental and Peace Education Center
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Utica Citizens in Action
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Finger Lakes Group of the Atlantic Chapter, Sierra Club
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Families Against Incinerator Risk
Salt Lake City, Utah
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Jersey Shore Nuclear Watch
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Pennsylvania Consumer Action Network
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El Paso Solar Energy Association
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Nuclear Free Takoma Park Committee
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Vice Chair
Mankato Area Environmentalists (MAE)
170 Good Counsel Drive
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Friends of the Coast - Opposing Nuclear Pollution
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Des Moines, IA
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DOE Office of Civilian Radioactive Waste Management, Ivan Itkin
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United States House of Representatives