INEEL NEWS
Environmental Defense
Institute
News and Information on
Idaho National Engineering and
Environmental Laboratory
|
October 2001 |
Volume 12
Number4 |
Through violence you may murder a murderer, but you can't murder murder.
Through violence you may
murder a liar, but you can't establish truth.
Through violence you may
murder a hater, but you can't murder hate.
Darkness cannot put out
darkness. Only light can do that.... -- Martin Luther King, Jr.
Satyagraha is a process of
educating public opinion, such that it covers
all the elements of the society and
makes itself irresistible.
Satyagraha is a relentless
search for truth and a determination to search
truth.
Satyagraha is an attribute of
the spirit within.
Satyagraha has been designed
as an effective substitute for violence. -- Mahatma Gandhi
People from around the world are grieving and share the immense sadness of the
families and friends of the victims of the tragedies.
The staff of the Institute for Energy and Environmental Research (IEER) grieves
with them. I have written this message and
these suggestions for resistance to violence and terror and militarism at the instance of
and on behalf of the entire IEER staff.
The September 11 events of global terror cry out for and deserve a global response
to help make the world as secure as we can from the threat of mass destruction. This was not the first or the most devastating
event of mass destruction. As is well known,
air warfare was created in the twentieth century as an instrument of state terror to
entirely neutralize or destroy “vital
centers” - that is, cities, thereby obliterating the difference between combatants
and non-combatants in war. (A brief history
of air warfare doctrine is posted on IEER’s website www.ieer.org.) Nuclear weapons extended the terror of
conventional explosive bombing and fire bombing to a new dimension. But September 11, 2001 has nonetheless created a
dreadful watershed in world history. The
preponderance of evidence indicates that a non-state party, a terrorist network, has now
used civilian aircraft as weapons of mass destruction to kill thousands.
The possibility that terrorists may create destruction on a vast scale has until
now been postulated in studies and hinted at by many actual acts of terrorism such as the
1995 Oklahoma City bombing of the Alfred P. Murrah Federal Building, the 1993 bombing of
the World Trade Center, and the 1995 chemical attack on a Tokyo subway. But the enormous
scale and coordination of the assault, the choice of targets, the years of preparation,
and the results of the September 11, 2001 attack mean that what was once largely
hypothetical has moved into the column of grim reality.
The risk of continued terrorist attack remains, according to the U.S. government. Retributive violence would add to the risks of
continued terrorism, and it may also add to the risk of escalation to the use of nuclear,
chemical, or biological weapons by a terrorist group.
We do not know if some non-state groups already have nuclear materials. And we do not know how much they might have, if
they do. Specifically, instability and
conflict in Pakistan, a nuclear-armed state, over cooperation with U.S. military actions
might have unpredictable consequences.
It is imperative that we try to persuade the U.S. government against a policy of
violence and for a process that will lead to capture of the suspects and a trial.
Moreover, if eradication of terrorism is the overall goal, a trial of the suspected
plotters and financiers would reveal more about how terror networks are organized and
maintained than a violent elimination of the suspects. The Nuremberg trials not only
brought many of the perpetrators of the Holocaust to justice but also revealed great
detail about how it was organized and implemented. They
also led to important advances in international law.
A trial in relation to the September 11 attacks would also show the world the best
side of the traditions of the United States: the struggle for the rule of law and justice
that motivated the American constitution, which has inspired not only generations of
Americans but also freedom fighters worldwide.
But we need more than a trial. We
need a process will lead to a progressive diminution of the conflicts and hatreds that
lead up to acts of terror and indiscriminate killing.
It is widely recognized that they are rooted in the terrible injustices and
inequities that characterize our world. Reducing
violence requires a reduction in militarism and repression by states and a systematic
reduction of the great inequities in the world, so that people can have hope instead of
despair. One analysis and discussion of the
world economic and military structure as a kind of global apartheid (with some important
differences) can be found in a July 9, 2001 article in The Nation by Salih Booker and William Minter. Another can be found in my book, From Global Capitalism to Economic Justice, (Apex
Press, 1992, reprinted in 1996), along with a discussion of possible approaches to reduce
global inequity and violence.
Given the level, scale and geographical spread of inequity, injustice, and anger in
the world, it is likely that violent retribution by the United States would lead to global
disunity and more conflict. It would increase
the likelihood of more terrorist attacks, possibly more devastating ones. Such a prospect would be made more likely if U.S.
retribution produces large-scale civilian casualties.
Oil is and has been, through much of the twentieth century, one of the central
aspects to the violent tangle of Middle Eastern, Central Asian, U.S., and world politics. The Japanese attack on Pearl Harbor came after the
U.S. imposed an oil embargo to prevent Japan from getting access to and eventual control
of Indonesian oil, which belonged neither to Japan, nor to the United States, nor to the
Dutch colonialists who then ruled Indonesia. As
another example, the CIA-supported overthrow of an elected government in Iran in 1953 (in
reaction to nationalization of the Iranian oil industry) and its replacement by the Shah
of Iran led to two and a half decades of repression in which substantial dissent was only
possible in the mosques. The process was
central to the dynamic that led up to the 1979 Islamic revolution in Iran. For an excellent history of oil politics, see
Daniel Yergin, The Prize: The Epic Quest for Oil,
Money and Power, (New York: Simon and Schuster, 1991).
For a fine, recent analysis of Central Asian oil resources and U.S. policy see
Michael Klare, Resource Wars: The New Landscape of
Global Conflict, (New York: Metropolitan Books, 2001).
Much U.S. policy in the Middle East makes for alliances with undemocratic regimes,
including the one in Saudi Arabia, where, as in Afghanistan, no freedom of religion is
allowed. That the Saudi Islamic government
has allowed the stationing of U.S. troops in Saudi Arabia, which has the two places most
sacred to Muslims as well as the largest oil reserves in the world, has been in the center
of the anger of some Islamic militants of the region.
(See for instance a TV interview with Osama bin Laden partly conducted by ABC news
correspondent John Miller in 1998 at http://www.pbs.org/wgbh/pages/frontline/
shows/binladen/who/interview.html. See also
Mary Ann Weaver's article on Osama bin Laden in the New Yorker at http://www.newyorker.com/FROM_THE_ARCHIVE/ARCHIVES/?010924fr_archive03 and John K. Cooley, Unholy
Wars: Afghanistan, America and International Terrorism, Second Edition, (London, Pluto
Press, 2000).) And as is increasingly
recognized, those angry militants largely come from the phase of U.S. policy that funded
and trained them in the 1980s to oust the Soviet military from Afghanistan. Later, the Taliban was partly funded by Saudi
Arabia until the 1998 bombings of the U.S. embassies in Kenya and Tanzania. (For a brief history of the Taliban, see Ahmed
Rashid, “The Taliban: Exporting Extremism,” Foreign Affairs, November/December 1999, pp.
22-35).
If retribution and violence are the wrong answers, how can the people of the world
work together to pursue justice and increased security?
Active, non-violent resistance to evil that goes to the root of the problem in a
manner that everyone could participate was the hallmark of the Gandhian struggle for
India’s independence, known as Satyagraha,
as it was of the U.S. civil rights movement, and the anti-apartheid struggle in South
Africa. Making salt, making cloth, and
desegregating lunch counters and buses were everyday acts that mobilized millions.
The Gandhian struggle in India had a part of its inspiration in U.S. history - in
the acts of Henry David Thoreau in the mid-nineteenth century to resist an unjust war and
slavery. The civil rights struggle led by
Martin Luther King, inspired in part by Gandhi’s example, was non-violent resistance
to injustice returning to the United States. This
rich history can perhaps provide us with the inspiration we need in these grim and sad
days to find ways to resist the violence both from weapons of mass destruction but also
from injustice and exploitation that has come to characterize global society. More than
five hundred million children have died needless deaths from starvation, lack of clean
water, and lack of elementary medical care since World War II. At the same time, the wealthiest 400 people
control more wealth than the poorest two billion. Maintenance
of such inequalities requires a vast and global repressive machinery that has led to many
valiant struggles for justice, but also bred hopelessness, anger, and hate.
October 2 is Gandhi’s birthday. Perhaps
it can be a day when we can all reflect on what we might do individually, in our
communities, and on a global scale to resist militarism and violence, whether it comes
from non-state groups or from states and to help create security, peace and justice.
For instance, one way in which those of us who live in the West and consume more
than our fair share of fossil fuels can resist the cynical and militarist politics of oil
be to reduce our petroleum consumption as much as we can.
A 25 percent reduction in oil consumption in the wealthy countries would amount to
about 10 million barrels a day - more than the production of Saudi Arabia, which is the
world’s largest oil exporter. That
could change the face of oil politics. While
we cannot completely eliminate the use of oil in short and medium term, it would cause
immense economic dislocation and suffering - significant voluntary reduction of oil
consumption as well as sensible policies to that same end could help create a direction of
greater equity, security, and environmental sanity. The
soldiers who may be sent to fight in the desert sands, or those who are already there,
with oil as a prime objective, would breathe easier too.
(For an analysis of the proposed Bush administration energy policy and for
IEER’s energy policy recommendations see Science
for Democratic Action, vol. 9 number 4, August 2001, on IEER’s web site, www.ieer.org.)
Another idea that has been put forth is to send food to the villages of Afghanistan
instead of bombs. That act of love might
create cooperation from the heart that may increase the chance that there will be a trial
instead of cycles of escalating violence. The
official rhetoric in Washington makes it seem unlikely that the U.S. government would, at
this stage, take actions friendly to the people of Afghanistan - indeed it is in the
contrary direction.
How people to people diplomacy might be conducted around the world to create a
direction of peace at time when the talk of war is so loud is a major challenge, to say
the least. But Nelson Mandela, the African
National Congress, and the people of South Africa joined by people all over the world used
Gandhi as an inspiration to get rid of apartheid in South Africa. We now need a bigger struggle that taps into the
same roots to get rid of global apartheid.
It will take the cooperation of organizations and people of goodwill around the
world to rise to the challenge. We
might begin this October 2 by gathering in our communities to remember those who died in a
common global disaster and to ponder what we might do together across national boundaries
that would honor the global nature of the tragedy and prevent its repetition. At meetings
around the world on that date, we might gather to consider the questions of justice and of
finding a path away from global apartheid, global violence and militarism, whether by
states or terrorist groups, and towards global democracy, justice, equity, and friendship.
Ä
Arjun Makhijani is President of the Institute for Energy and Environmental Research
and this article is reprinted with the author’s permission.
Time for Introspection |
During this time of national crisis the last thing most people do is sit down and
wonder why such terrible attacks could be launched at America, the country that we think
of as the seat of democracy and the world’s advocate for human rights
and the rule of law. Crisis does not lend
itself to self-assessment about the
“cause
and effect” elements that thrust this ugly reality right into our faces. But more than ever, before we place our
precious American solders into harm’s way, we as a nation must first step back, take
time to think about the big picture.
This is a crucial time in the history of America.
It is as if FDR might have said, another “Day
of Infamy.” However, we simply cannot
afford to make the same mistakes of the past.
Clearly, there was a terrible attack on the World Trade Center and the Pentagon in
Washington resulting in the tragic death of many thousands of innocent folk from all
countries and hundreds of courageous first emergency responders, but we must take time to
reflect on the “why’s” in order to rationally plot America’s
collective military, political, economic, and ethically moral path forward.
Our 1998 retaliatory Cruise missile attacks on Afghanistan and the Sudan, after the
bombing of two U.S. embassies in Africa, we now know destroyed a mosque and a legitimate
pharmaceutical distribution center, neither of which was connected with Osama bin Laden. The reliability of “military
intelligence” has not improved since we mistakenly bombed the Chinese Embassy in
Belgrade under the pretext of killing Sloveden Milosovick, or the bombing of a Baghdad
underground shelter that killed hundreds of Iraqi civilians in our attempt to assassinate
Saddam Hussein. America must
collectively stop and learn from these past errors otherwise the needless killing will
only continue.
Susan Sontag’s commentary in a recent
(9/11/01) New Yorker Magazine Talk of the Town
article notes: ”The disconnect between
last Tuesday's monstrous dose of reality and the self-righteous drivel and outright
deceptions being peddled by public figures and TV commentators is startling, depressing.
The voices licensed to follow the event seem to have joined together in a campaign to
infantilize the public. Where is the acknowledgment that this was not a
"cowardly" attack on "civilization" or "liberty" or
"humanity" or "the free world" but an attack on the world's
self-proclaimed superpower, undertaken as a consequence of specific American alliances and
actions?
How many citizens are aware of the ongoing American bombing of Iraq? And if the
word "cowardly" is to be used, it might be more aptly applied to those who kill
from beyond the range of retaliation, high in the sky, than to those willing to die
themselves in order to kill others. In the matter of courage (a morally neutral virtue):
whatever may be said of the perpetrators of Tuesday's slaughter, they were not cowards.
Our leaders are bent on convincing us that everything is O.K. America is not
afraid. Our spirit is unbroken, although this was a day that will live in infamy and
America is now at war. But everything is not O.K. And this was not Pearl Harbor. We have a
robotic President who assures us that America still stands tall. A wide spectrum of public
figures, in and out of office, who are strongly opposed to the policies being pursued
abroad by this Administration apparently feel free to say nothing more than that they
stand united behind President Bush. A lot of thinking needs to be done, and perhaps is
being done in Washington and elsewhere, about the ineptitude of American intelligence and
counter-intelligence, about options available to American foreign policy, particularly in
the Middle East, and about what constitutes a smart program of military defense. But the
public is not being asked to bear much of the burden of reality. The unanimously
applauded, self-congratulatory bromides of a Soviet Party Congress seemed contemptible.
The unanimity of the sanctimonious, reality-concealing rhetoric spouted by American
officials and media commentators in recent days seems, well, unworthy of a mature
democracy.
Those in public office have let us know that they consider their task to be a
manipulative one: confidence-building and grief management. Politics, the politics of a
democracy which entails disagreement, which promotes candor has been replaced by
psychotherapy. Let's by all means grieve together. But let's not be stupid together. A few
shreds of historical awareness might help us understand what has just happened, and what
may continue to happen. "Our country is strong," we are told again and again. I
for one don't find this entirely consoling. Who doubts that America is strong? But that's
not all America has to be.” (For more
compelling info see New Yorker Magazine commentary at
http://www.newyorker.com/ )
Although Susan Sontag failed to cover all relevant bases in this issue of national
crisis, she admirably covers crucial topics least covered by the current main-stream media
for which she deserves credit. Commentary in The Nation Magazine ( www.thenation.com)
offers equally compelling analysis on recent events. Ä
Nuclear Terrorism - How Long can U.S.
Luck Hold Up?
By David B. McCoy
|
The Bush administration’s call to proceed with an expansion of nuclear power
as an energy resource must be looked at as an invitation to subject ourselves to the worst
type of terrorism imaginable. The terrorist attack on NYC and the Pentagon were striking
for the high profile loss of life and a warning about the lack of security of
America’s airspace.
Despite the ensuing agonies of these attacks, the targets chosen were certainly not
the targets which could have inflicted the worst damage to the Eastern US. The US has 103 nuclear reactor sites storing
enormous amounts of spent fuel from prior years of operations in large cooling pools.
The operating cores of these reactors can experience meltdown and hydrogen
explosions which can spread radioactive contamination over hundreds if not thousands of
square miles. Numerous Department of Energy
sites contain enormous amounts of radioactive materials and nuclear wastes from weapons
production. DOE’s operating reactors (like INEEL’s Advanced Test Reactor) do not
have the containment buildings required of commercial reactors. Evacuation plans in the event of terrorist attack
on nuclear facilities are laughable. Insurance
liability is statutorily limited.
The Eastern seaboard of the US has a heavy concentration of nuclear reactor sites--
many with highly visible cooling towers. Any of these sites could have been attacked
without defense by the airplanes which were used in the World Trade Center attack. Three
Mile Island, Peach-bottom, Millstone, Oyster Creek, Salem Hope Creek, Calvert Cliffs, and
Yankee Rowe are just some of the reactors within close proximity to where the aerial
attacks took place. The Chernobyl meltdown in
Russia caused some 32,000 deaths.
Aerial nuclear facility attacks could render the Eastern US unlivable or perhaps
uninhabitable for thousands of years. Nor
is the Western US immune from the danger. An
attack on the San Onofre or Diablo Canyon sites on the Pacific coast could have
unbelievable consequences for California.
The security systems of nuclear facilities are primarily geared towards fending off
ground based attacks of the facilities. The
Nuclear Regulatory Commission is currently proposing to reduce federal oversight and allow
power companies to design their own security systems.
This, despite reports that nuclear reactor sites have repeatedly failed to protect
against mock terrorist attacks, even with advance notice.
Having financially strapped utility companies design and operate budget-minded
reactor site security systems is not a comforting proposal.
While nuclear power facilities possibly have no defense against air attacks, far
less difficult strategies of attack upon such facilities are possible and the information
easily accessible within the public domain. Detonation
of explosives from remote controlled devices or hand operated rocket launchers to cripple
the offsite power supply and the onsite emergency power backup systems is a vulnerability
of nuclear plants in the US and the rest of the world.
High technology brings with it both risks from high technology and low
technology stratagems.
The increased transport of spent fuel
and nuclear materials throughout major cities in the US also presents severe potential
consequences.
Ä
Idaho Fails Test to Enforce Hazardous Waste Laws |
After a decade of serious and substantial non-enforcement of this nation’s
hazardous waste laws at the Idaho National Engineering and Environmental Laboratory
(INEEL), the Environmental Defense Institute, Keep Yellowstone Nuclear Free, and attorney
David McCoy filed a formal petition to the U.S. Environmental Protection Agency for
removal of the State of Idaho’s authority to enforce these laws. The petition also
seeks a stay of the EPA decision until the petitioner’s allegations to the EPA
Inspector General have been investigated and findings issued. EPA recently announced its intent to confirm final
enforcement authority on Idaho after a ten-year trial period intended to demonstrate
whether or not the State has the ability and/or political will to enforce federal
hazardous and radioactive waste environmental statutes.
The Petition alleges that Idaho failed to comply with laws controlling the handling
of high-level radioactive and mixed hazardous waste treatment operations while IDEQ was
under the oversight of the EPA. Hazardous
waste facilities were allowed to operate at lesser standards resulting in emissions such
as arsenic, beryllium, mercury and plutonium, which could not have occurred if IDEQ had
complied with federal regulations.
“In the interest of public health and welfare, the State Department of
Environmental Quality (IDEQ) must be held accountable for not fulfilling its mandate to
enforce the law.” notes Chuck Broscious,
Executive Director of the Troy, Idaho based Environmental Defense Institute.
Based on Freedom of Information Act and the Idaho version Public Information
Requests, it is clear that some of IDEQ’s technical staff made top-level agency
management aware that the hazardous waste laws were not complied with by the U.S.
Department of Energy that operates the INEEL. Tragically,
IDEQ management choose to ignore its own technical staff and implement a politically
motivated course of laissez faire inaction bowing to INEEL, the largest employer in the
state and one which wields enormous economic and political power in the State of Idaho.
"It is clear from our own experience that Idaho is unable or unwilling to make
the Department of Energy (DOE) follow the law," explained Erik Ringelberg, KYNF
Executive Director.
“The Idaho DEQ and the DOE have run operations in violation of federal and
state law over the last decade up to the present at an extreme risk to public health and
safety for ours and future generations. Political
collusion between state administrators and federal agencies has allowed illegal operations
and secret procedures which denied the public a full picture of these dangerous
operations, the improper permitting processes and planned projects,” states co-petitioner and Idaho Falls attorney
David McCoy.
The Environmental Defense Institute, Keep Yellowstone Nuclear Free and David McCoy
as Petitioners list the following demands:
For a copy of the Petition to EPA see
EDI’s website Reports Section:
http://home.earthlink.net/~edinst/
A Critical Analysis of
INEEL’s Proposed Radioactive and Hazardous Waste Dump: |
I have reviewed the design documents for the proposed INEEL CERCLA Disposal
Facility (ICDF), and have two initial concerns regarding the siting of this facility. The first is the location of the facility directly
in the documented "wind blown" soils contaminated by INTEC (ICPP) activities. The second is the siting of the facility in the
100-yr floodplain. In addition to the siting
considerations, I am greatly concerned about the use and potential health risks associated
with the [dump’s] radioactive and hazardous waste evaporators.
The siting of the facility in the wind-blown contaminated soils raises immediate
concerns with the initiation of the "test pad" activities, road and stockpiling
operations. In several conversations with DOE
and contract personnel, IDEQ, and [EPA], I have not heard any rationale for not protecting the public and onsite personnel from
radioactive and hazardous contaminated soils. Yet
I can find no detail on how the public and workers will be protected from re-suspension of
contaminated dust during site prep and use activities.
Quite frankly, there appears to be minimal recognition of even generic dust
management activities needed for ordinary construction, let alone working with documented
contamination. Since these activities have
already begun, it is important to address these considerations, or direct us to where this
documentation may exist.
1. The siting of the facility in the 100-yr floodplain is of obvious concern in
regards to flooding risk during operations and post-closure. Unfortunately, the DOE steadfastly denies that the
ICDF is located in the floodplain (Re., public comments by DOE Public Information). I submit that the information provided by all
documented sources available to the public shows that no other conclusion is possible.
USGS reports 98-4065 and 96-4163 document a 100-yr-flood level at INTEC of 4923 ft.
at a flow of 7,260 fps. The drawings
submitted by the DOE's contractor (870.120) place the terrain contours at the ICDF at
4919, 4921, and 4922 (E to W, respectively). That
unambiguously places the ICDF well within the 100-yr floodplain.
Further, the
same documents place the base of the excavated ICDF dump at 4884 ft, and the evaporator
4922 ft. with the sumps located even lower. Also,
well within the 100-yr floodplain. Therefore, the ICDF is located within the 100-yr.
floodplain.
Why was a location outside of the floodplain (and wind-blown contaminated soils)
not selected? How is it in the public
interest to construct a "permanent" facility within a 100-yr. floodplain, when
ready alternatives lay a few hundred meters away?
Is the 100-yr. floodplain delineation excessively conservative and thus arguably
still protective of human health and the environment? I believe that answer to be no. The USGS author notes that the model used does not
use the 95 percentile flow of 11, 600 cfs and instead uses 7,260 cfs flow; the model does
not include the likely failure of the Mackay reservoir (estimated at 45-55,000 cfs); the
model ignores road culvert clogging; and, it does not model lateral energy flows, such as
those encountered at Lincoln Rd. adjacent to the ICDF, (USGS 98-4065). The USGS readily accepts the limitations of this
modeling exercise and notes that it needs to do a 2-dimensional model to better understand
the complex floodplain interactions at INEEL. Therefore,
the ICDF is located within a 100-yr. floodplain that could additionally receive from 50%
to 760% more flow than the current model projects.
Since 40 CFR 264 Appendix VI specifically includes Bingham, Bonneville,
Clark, and Jefferson counties, has there been a formal determination of exemption by the
Administrator? Otherwise, the 40 CFR 264.18
description of "…chance in flooding in any given year from any source (.),"
would certainly include the ICDF site or relevant downstream impacts, and would further
include a Mackay reservoir failure of much greater magnitude.
It seems
remarkable to me that the regulations discuss the 100-yr. floodplain, [even if the DOE
does not] yet I have seen nothing in the documentation that addresses the even more
catastrophic 500-yr. flood. On a
probabilistic basis over the life of the ICDF, it would seem that the 500-yr. flood would
have the highest risk of exposing the public to tons of nuclear and hazardous waste. Yet, there is not any mention of this obvious risk
in any documentation provided to us.
What flood loads are the berms designed to resist and how has this been
documented? The only conclusion I can come to
is that in order for the ICDF to have any claim of being protective of human health and
the environment, the facility must be placed outside of the 500-yr. floodplain.
2. The radioactive and hazardous waste evaporators
present numerous concerns. First and
foremost, given the historic gross incompetence shown by the DOE in its waste
characterization (and the total lack of air monitoring at the evaporation ponds) how is
the public to be protected from air discharge of radioactive and hazardous waste; given
the sole intent of the evaporators is, by definition, to evaporate liquid radioactive and
hazardous waste into our air?
I find it hard to reconcile that these wastes are so toxic that they require
secondary containment of all containers and pipes, yet it is acceptable to put it in the
region's air. Dilution of contamination to
meet regulatory maximum limits is not legal under RCRA, yet in my opinion that is exactly
what this facility is designed to do.
Second, the documentation provided us by the DOE states in unclear terms
that the evaporators are also to be used to evaporate liquid waste derived from site-wide
CERCLA activities. What are the proposed
volumes of these additional wastes and how will these liquids be characterized?
Third, the
sump system is designed to capture liquid waste that penetrates the first liner. How does this system not by default concentrate radioactive and hazardous
material, which the EPA has told us will happen with certain nuclides and solvents? If this waste is concentrated in the sump, piping,
or evaporator bottoms, how will it not present a risk of criticality?
The EPA has done a tremendous service to the public by involving interest groups
during the design stages. After careful
analysis of the ICDF plans, it appears to me that the siting of this facility in such a
high-risk location should never have been allowed in the first place. There has never been any compelling reason to
locate the facility there, and the DOE's steadfast refusal to even acknowledge the basic
siting problems have perpetuated the problem.
Unfortunately, the Record of Decision
and supporting documentation that this project was based on leave much to be desired In my opinion, the document was
unnecessarily vague and conceptual at best. Lacking
even an index, it is unreasonable to expect the public to provide much detailed commentary
on such a document. And, even when public
commentary was received on the ICDF, it was apparently ignored. Where is the analysis of the cumulative impacts
of dozens of radioactive and hazardous waste evaporators?
Where is the analysis of the cumulative impacts of contaminating the region's air
for decades?
Ä
*Erik Ringelberg is Executive Director of Keep Yellowstone Nuclear Free, based in
Jackson WY. This article is excerpted with
the author’s permission from a letter sent to EPA Region X on 8/28/01. For more
information see www.yellowstonenuclearfree.com