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« Resisting environmental racism at Yucca Mountain, Nevada | Main | Nov. 9th update from NRC on Yucca Mountain public comment period »
Wednesday
Nov182015

Defend environmental justice -- speak out against Yucca Mountain dump by Nov. 20!

Yucca Mountain, Nevada is Western Shoshone Indian land, as recognized by the U.S. government when it signed the "peace and friendship" Treaty of Ruby Valley in 1863. Treaties are the highest law of the land, equal in stature to the U.S. Constitution itself.

As with Western Shoshone Indian Nation resistance to nuclear weapons detonations at the Nevada Test Site since 1951, the U.S. government has often attempted to ignore the tribe's protests against being targeted for the country's high-level radioactive waste dump at Yucca Mountain.

Most recently, the U.S. Nuclear Regulatory Commission (NRC) has attempted to revive the Yucca dump proposal, even after President Obama cancelled it in 2010 as "unworkable," a nod to the State of Nevada's tireless opposition.

(NRC published notification of its Yucca Mountain high-level radioactive waste dump Draft Supplemental Environmental Impact Statement (DSEIS) in the Federal Register on Aug. 21. The DSEIS is posted on NRC's website.)

Western Shoshone resistance has been tireless as well. Ian Zabarte, of Deebege Newe and the Native Community Action Council, has long resisted the environmental racism inherent in the Yucca dump proposal. He has prepared an action alert for tribal environmental leaders. [On November 20th, Ian Zabarte's "NATIVE AMERICANS BELIEF IN WATER: AN ENVIRONMENTAL JUSTICE CONTEXT" was submitted, as part of the State of Nevada Agency for Nuclear's Project's official comment to NRC; see Appendix C, beginning on page 80 of the PDF counter. See also the COMMENTS OF THE TIMBISHA SHOSHONE TRIBE, Appendix B, beginning on page 68 of the PDF counter.]

The Yucca dump, if ever opened, would leak massively into the groundwater below. That groundwater eventually surfaces as springs in Death Valley, CA, putting the Timbisha Shoshone who live there at radiological risk.

Corbin Harney (standing) and Raymond Yowell, former chief of the Western Shoshone Indian Nation, at Peace Camp, protesting the Nevada Test Site and Yucca dump in October 2002. Photo by Gabriela Bulisova.Poo-Ha-Bah -- Newe (Shoshone) words meaning "Doctor Water" -- is a nonprofit 501(c)(3) organization located at healing hot springs in Tecopa, CA. It is also downstream of Yucca, and thus at risk if the dump ever opens. It was founded in 1998 by Newe Spiritual Leader Corbin Harney (1920-2007, photo left), and is now under successive leadership of Darlene Graham, and a majority Native American Board of Directors with traditional knowledge. Corbin Harney helped lead resistance to nuclear weapons testing and radioactive waste dumping on Newe land for decades on end.

Please help defend environmental justice, against radioactive racism, by submitting public comments opposed to the Yucca dump. Public comments are due by 11:59pm Eastern, Friday, Nov. 20. Read on to see how to submit comments.

Per the Fed Reg Notice, comments can be submitted:

via the Federal Rulemaking Web site: Go to http://www.regulations.gov and search for Docket ID NRC-2015-0051;

or, by mailing comments to Cindy Bladey, Office of Administration, Mail Stop: OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regarding WHAT comments to make, see the ideas below. You can use those to write your own. Be sure to specifiy the report number NUREG–2184, as well as the Docket ID NRC-2015-0051, in the subject line of your comments, so they can be routed to the correct docket.

SAMPLE COMMENTS [see additional sample "Talking Points," update below]

NRC's DSEIS has absurdly concluded that radioactive releases from the proposed Yucca Mountain high-level radioactive waste dump would be SMALL -- that is, essentially minimal, and harmless -- over the course of a million years into the future.

Actually, if irradiated nuclear fuel is ever buried at Yucca, it would leak massively, into the groundwater, creating a "nuclear sacrifice zone" over a broad region downstream.

This would include hazardous, even deadly, radioactive contamination of the groundwater, currently used for drinking and irrigation water in Nevada's agricultural Amargosa Valley; the Ash Meadows National Wildlife Refuge, Death Valley National Park, as well as the Timbisha Shoshone Indian community inhabiting Death Valley, would also be in harm's way.

The potential for disproportionate impacts on minority or low-income populations is especially high, considering the current lifestyle of the Timbisha Shoshone Indian community, as well as the traditional lifestyle of the Western Shoshone Indian Nation.

The potential for cumulative impacts associated with other past, present, or reasonably foreseeable future actions is very high. After all, the U.S. Atomic Energy Commission, Department of Energy, and military conducted atmospheric nuclear weapons tests in the vicinity of Yucca Mountain from 1951 to 1963. They continued to conduct underground full-scale nuclear weapons tests at the Nevada Test Site (NTS) from 1963 to 1992, many of which leaked radioactivity to the atmosphere and environment, as well as contaminated regional groundwater. Even after 1992, nuclear weapons testing has continued at the NTS, in the form of sub-critical experiments involving plutonium.

Another cumulative impact involves the large-scale transport to, and dumping of so-called "low" level radioactive wastes at, the NTS.

We join with the State of Nevada Agency for Nuclear Projects, several environmental groups, and others in urging NRC to extend the public comment deadline by at least an additional 60 days. We also urge that additional in-person public meetings be scheduled in California (where Yucca's radioactively contaminated groundwater would ultimately surface in springs), as well as elsewhere across the country (given that Yucca's opening would launch the unprecedented, large-scale shipment of risky high-level radioactive waste by truck, train, and barge, through most states. And we urge that all in-person public meetings also include the call-in option, already provided at other locations, on earlier dates.

Frame of a Western Shoshone sacred ceremonial sweat lodge, with Yucca Mountain in the background, Oct. 2002. Photo by Gabriela Bulisova.And lastly, WHY to comment? A thousand environmental groups, representing every state in the Union, have joined with the Western Shoshone Indian Nation, as well as the State of Nevada and its U.S. congressional delegation, ever since the "Screw Nevada bill" of 1987, to stop the dangerous Yucca Mountain dump. Now is no time to let up the resistance. (This listing of 750 groups, posted online, was later updated to show more than a thousand groups opposed to the Yucca dump.)

More sample talking points, shared by Mary Olson of NIRS SE, you can use to prepare your own:

HOW does NRC account for the inclusion of High-Burnup Fuel in the Yucca Mt post-closure impact analysis?

If NRC is not factoring High-Burnup fuel as waste, then it is not accurately assessing these factors, all of which impact the post-closure impacts:

Heat load (including over time);

Source Term (ditto);

Mobility of radionuclides in the source-term profile.

If the amount of radioactivity, the type of radioactivity and its contribution to the heat issues are wrong, then the Total System Performance Assessment (TSPA) used to project the post-closure outcomes should be corrected and the Draft SEIS tabled until the TSPA is corrected.

FOR MORE ON HIGH-BURNUP WASTE, See Donna Gilmore/Marvin Resnikoff’s fact sheet on High Burnup Fuel:

http://sanonofresafety.org/2014/01/08/high-burnup-fuel-fact-sheet-2/

And Donna’s report on NRC ignoring High Burnup as an issue in nuclear waste transport: (Strong circumstantial evidence that NRC has also ignored High Burnup issues in the matter of Yucca Mt.)

http://sanonofresafety.org/2014/02/21/nrc-ignores-high-burnup-in-spent-fuel-transportation-risk-assessment/

Here is a different version from NV Nuclear Waste Task Force:

Regarding high burn-up - If there is not the 7,000 MTU [Metric Tons Uranium] of defense waste in the repository it could possibly be made up by adding more commercial waste to fill the 70,000 MTU statutory capacity. Some or all of that 7,000 MTU could be high burn-up which becomes a TSPA problem, because it does not consider high burn-up fuel (above 45 Gwd -- Giga-watt days) in its calculation. This could be an additional contributor to the assertion that the starting point contaminant concentration for the SEIS has no credible technical basis.

To learn more about Yucca Mountain, see Beyond Nuclear's website section, as well as NIRS's website section.