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Mulga Rock - last chance - Containment film screening + news

This coming Tuesday submissions for the Mulga Rock uranium mine proposal will close. This will be the last of the uranium mine assessments for a long time - we really need your help to send as many submissions as possible to the EPA. Mulga Rock is home to many rare and endangered species, in a unique part of the Great Victoria Desert. his proposal is for multiple open pits, 15 million litres of water a day, clearing 3,709 ha and leaving behind 30 million tonnes of radioactive tailings. The project is headed up by Vimy Resources - a company made up of former FMG execs, execs from the Minderoo Group, former Liberal MPs and 27% owned by Twiggy Forrest.

Next Friday - 11th March CCWA and Tugg are hosting the WA Premiere screening of Containment, made by two harvard professors, exploring some of the challenging issues about the world's nuclear waste - never has this film been more relevant as the South Australian debate on nuclear has narrowed to a proposal to store international radioactive waste. Book your tickets here: $15 concession, $20 general, $25 solidarity. 

Remember to tune in to Understorey – and the Radioactive Show this week for all the latest nuclear and peace news. Thanks to Libby for the ongoing supply of news! 


SPECIAL EVENT: Containment Film Screening
Cinema Paradiso - 164 James St Northbridge 
Friday 11th March - 5th Anniversary of Fukushima 5.30-730pm 
Join us on the 5th anniversary of the Fukushima disaster for the screening of the award winning new documentary film "Containment" by two harvard professors - exploring the very real issue of managing the worlds nuclear waste. Funds raised will go to support the important work of the Rainbow Stay project - offering respite to children from Fukushima. Book your ticket here

ONLINE ACTION: No uranium mine at Mulga Rock 
Thanks to people like you the EPA has received over 15,000 submissions against the Kintyre, Yeelirrie and Wiluna uranium mine proposals. Now there is one more - Mulga Rock. We need your help again to send a message to the EPA against the uranium mine plans at Mulga Rock an ancient and fragile landscape in the heart of our outback country upstream from the Queen Victoria Springs Nature Reserve. Mulga Rock is home to the unique marsupial mole, sandhill dunnart and brush tailed mulgara. Plans for the mine include clearing 3,709 ha of native vegetation replacing it with 14 waste rock piles and 9 open pits. This mine and processing facility would take up to 15 million litres of groundwater and leave behind 32 million tonnes of radioactive mine tailings. Take Action now. 

KARLALMYI WALK: 5th - 12th June 2016 Registrations are open: 

"Come with us (Martu) we’ll walk to stop the uranium mining on our country. We’ll walk through Karlamilyi, not far, across Karlamilyi river. Walk through Lullapakujarra up to Punumullara then to Puljcatja - big water, up to Desert Queen Baths and then Kintyre."

WALKATJURRA WALKABOUT: August 2016 (stay posted for details) 

BUMP IS BACK: Next BUMP collective meeting - 15th March 6pm st Clancy's fish bar in Fremantle. 

HOST A FILM SCREENING - A film by an international film maker Rez - following the 2015 Walkatjurra Walkabout will be available soon for people to host a film screening with your friends and family. Contact Lucy or Marcus

VOLUNTEER: Australia Nuclear Free Alliance 2016
We are starting early with plans for a major event in Kalgoorlie in September 2016. We are looking for volunteers to get involved in making this event the show stopper of the campaign we need ahead of the 2017 state election. Call Mia to find out more - 0415380808 



Coalition digs deeper into fossil fuels with new “growth centre”The federal government has announced the establishment of a $15.4 million fossil fuel “growth centre”, to help prop up Australia’s oil, gas, coal and uranium sectors during what it describes as a “challenging time” for the industry. 

Ben Parr: Fossil fuel growth centre harks back to old ideas about climate costsDo fossil fuels need saving from efforts to combat climate change? The Australian government seems to think so, but that sort of thinking is out of date.On Wednesday, the minister for industry, innovation and science, Christopher Pyne, launched a new “growth centre” for Australia’s fossil fuel industry (and uranium), to be known as National Energy Resources Australia. The government will invest A$15.4 million over four years in the centre, which seeks to make coal and gas firms operating in Australia more competitive with fossil fuel firms operating overseas.   

Cutting Climate Science, Funding Fossil Fuels’ Growth: Welcome To The Age Of InnovationJust weeks after we learned budget cuts to the Commonwealth Scientific and Industrial Research Organisation (CSIRO) will force the loss of 110 climate researchers at the agency, the Federal Government is funding a new ‘growth centre’ for the fossil fuel industry.Christopher Pyne, the Minister for Industry, Innovation and Science, announced this week that the government will be providing $15.4 million to the oil, gas, coal and uranium sectors. the 24/2/16 media release ‘Energy Resources Growth Centre launched’ on Christopher Pyne’s web site at: 

A New Era of Collaboration for Oil, Gas and Energy Resources in Australia24 February 2016. The newly established National Energy Resources Australia (NERA), which is one of six Growth Centres that form part of the Australian Government’s $248 million Industry Growth Centres Initiative, is set to enable growth through industry-led collaboration, innovation and knowledge-sharing. ...The National Energy Resources Australia (NERA) enables growth in the oil, gas, coal and uranium sectors through industry-led collaboration, innovation and knowledge-sharing. NERA is one of six Growth Centres as part of the Australian Government’s $248 million Industry Growth Centres Initiative. NERA is headquartered in Perth, with nodes in Brisbane and Adelaide to come. The NERA headquarters is co-located with the Western Australian Energy Research Alliance (WA:ERA), and the National Resource Sciences Precinct (NRSP), at the Australian Resources Research Centre (ARRC) in Technology Park, Perth. NERA will work with the oil, gas, coal and uranium sectors to unlock commercial opportunities and drive innovation by building links between businesses and industry organisations, training providers and the science and research sector. Its role is one of facilitation, networking, activation not duplication. reading:

WA loses in BHP shake-up... WA iron ore’s most senior BHP executive will be asset president Edgar Basto, previously vice-president of Pilbara mine production, who will continue to be based in Perth and report to Mike Henry, one of the big winners in the management reshuffle to emerge as president operations, minerals Australia.Mr Henry, previously BHP coal boss, now has a remit which includes iron ore, Nickel West and the Olympic Dam copper-uranium asset.



Lots of links to media stories on the delegation of 20 people to Canberra yesterday - representatives from each of the six nominated sites for a national nuclear waste dump went to Canberra to meet with politicians to express their opposition to the nomination process and to hosting the nations most dangerous wastes.

Anica Niepraschk: 'Community consent' without community?

29 February 2016. The federal government - once again - is looking for a place to dump its nuclear waste. All attempts over the last twenty years have failed – and so might this one, at least if the government is sticking to the promises it made in its new approach.

Australian Greens Media Release: Liberal and Labor vote to ignore waste dump community concerns
22 Feb 2016. The Labor and Liberal parties have voted together against a senate motion acknowledging the community opposition to each of the six locations shortlisted as a site for a nuclear waste dump.
"It's not as though this motion asked a lot of the government, but for the opposition to cower from it is disappointing and weak," Australian Greens Deputy Leader and Nuclear Issues Spokesperson Senator Scott Ludlam said today.

MAPW Media Release: Failure of informed consent? Government information on nuclear waste is misleading and omits important facts.
Monday 22 February 2016 – MELBOURNE:  Nuclear medicine has been highlighted as a key reason to have a nuclear waste repository. MAPW President, Dr Margaret Beavis observes that ‘The Commonwealth government fact sheet: Information for communities- Key questions answered is a gross misrepresentation and reads more like a puff-piece for the nuclear industry. The recently released brochure states “One in two Australians – everyone who has ever had a broken bone, heart scan or cancer diagnosis – will need nuclear medicine at some point in their lifetime. “

Geoff Currie: Nuclear medicine comes from nuclear reactor
The anti-nuclear brigade's argument that you don't need nuclear reactors to produce nuclear medicine is factually inaccurate.
Flinders Ranges communities divided over whether to host Australia's planned nuclear waste dump
Communities in South Australia's Flinders Ranges remain deeply divided over whether nuclear waste should be stored near Hawker 

Traditional owners in the Flinders Ranges say nuclear waste dump threatens cultural heritage
Traditional owners in the Flinders Ranges say a Federal Government nuclear waste dump could destroy significant cultural heritage and countless sacred sites around a permanent spring.


Jobs, nuclear waste concerns face SA Government ministers on Port Augusta, Quorn visit
The future for regional employment will be high in residents' minds at a public forum at Port Augusta on Sunday evening, ahead of a South Australian Government country cabinet meeting at Quorn on Monday.

John Spoehr: SA’s Nuclear Waste Boom: A Hot Story Requires Cool Heads
February 26, 2016. As the alluring prospect of a nuclear waste storage boom fades a little in our minds, attention needs to turn to the risks associated with large–scale radioactive waste storage.

Michele Madigan: Nuclear waste danger knows no state borders
09 February 2016. The South Australia Royal Commission into the nuclear fuel cycle will give its interim report at the Adelaide Town Hall at 6pm next Monday 15 February.

How a nuclear dump could save SA's environment
State Labor whip Tom Kenyon continues to advocate for a nuclear storage facility - arguing the billions generated could safeguard the state's national parks and revive its agricultural land.


Dick Smith nukes talk of “cheaper” alternative energy in Far North
ELECTRONICS business founder Dick Smith says the Mt Emerald Wind Farm won’t make any difference to energy costs in the Far North.



Global wind power capacity tops nuclear energy for first time
The capacity of wind power generation worldwide reached 432.42 gigawatts (GW) at the end of 2015, up 17 percent from a year earlier and surpassing nuclear energy for the first time, according to data released by global industry bodies.


Stigmatize and Prohibit: New UN Talks on Nuclear Weapons Start Today
21 Feb 2016. ... The United Nations Secretary-General has said, "There are no right hands for the wrong weapon". But many in the international community often act with implicit acceptance of American, British, French, Russian, and Chinese nuclear weapons.
The "Humanitarian Initiative", however, is challenging this implicit acceptance. Through a series of international conferences on the humanitarian consequences of nuclear weapons and a formal pledge to "fill the legal gap for the prohibition and elimination of nuclear weapons" endorsed by 123 governments, non-nuclear weapon states are working to stigmatize, prohibit and eliminate nuclear weapons.
United Nations Working on Legalisation of Absolute Nuclear Disarmament
February 22, 2016. United Nations is fighting its way to legalise absolute nuclear disarmament. The decision was made after North Korea’s nuclear weapon test in January, as well as the United States’ mock test for more usable nuclear weapons.

Mexico issues alert after theft of radioactive material
Five Mexican states have been put on alert after a truck carrying a container of potentially dangerous radioactive material was stolen, the Interior Ministry says. 


Radiation from Fukushima nuclear disaster not found in B.C. salmon
Feb. 23, 2016. Five years after the Fukushima nuclear accident in Japan, radioactive contaminants continue to circulate across the Pacific to Canada’s West Coast, but not at dangerous levels.


China Inc.’s Nuclear-Power Push
In a shift, Chinese state-owned companies seek to roll out advanced reactors for export, a move that adds new competition for already struggling global firms.
Feb. 23, 2016. SHENZHEN, China—China wants to shift from customer to competitor in the global nuclear industry as it seeks to roll out its first advanced reactor for export, a move that adds new competition for already struggling global firms. &


Negotiations over establishment of Dabaa nuclear plant ongoing: Minister of Electricity
February 21, 2016.Egyptian minister of Electricity and Renewable Energy, Mohamed Shaker, said the ministry is still negotiating with Russia’s Rosatom over technical, financial, and technological agreements to establish the first Egyptian nuclear power plant in the Dabaa area.


France pledges more compensation for Polynesia nuclear tests.

Feb 22, 2016. Residents of French Polynesia who suffered due to 30 years of French nuclear tests in the Pacific archipelago have a legitimate right to compensation, President Francois Hollande said on his first visit to the region on Monday. &

R** The End of the Nuclear Age
Feb 24, 2016. Even before the Fukishima disaster, it was clear that nuclear power was dangerous, unreliable and too risky for civil use. The growth of renewable energy is now rendering them obsolete, argues Handelsblatt's energy expert.
Picking Up the Nuclear Tab
Feb 23, 2016. A leaked draft report on Germany's exit from nuclear power recommends the nation's four big utilities foot the €19.7 billion bill for decommissioning their power plants - but any costs above that may be carried by taxpayers.
German nuclear exit plan fails to solve waste storage puzzle
Feb 23, 2016. When Germany committed itself five years ago to phasing out nuclear power by 2022, there was one big gap in its plans -- what to do with the waste that can remain toxic for hundreds of thousands of years.
Nuclear commission proposes firms transfer cash by 2022 to pay for clean-up
Feb 22, 2016.BERLIN Feb 22 (Reuters) - Germany's utilities will have to transfer provisions set aside to pay for the interim and final storage of nuclear waste to a fund in cash by 2022, according to a draft report from a government-appointed committee seen by Reuters on Monday.

How American Penalties Dwarf the Liability US Nuclear Firms Will Face in India
Feb 21, 2016. A $48-billion (Rs 3.26 lakh crore) penalty claimed by the US government from Volkswagen for cheating on diesel-car emissions is about 200 times as large as the $225 million (Rs 1,500 crore) insurance pool set up by Indian insurance companies to compensate US nuclear companies for mishaps in India.


Former TEPCO bosses indicted over handling of 2011 Fukushima nuclear disaster
Three former TEPCO executives have been indicted over their handling of the 2011 Fukushima nuclear disaster, in what is the first criminal trial linked to the crisis 
Charges near for former TEPCO executives over Fukushima nuclear disaster.
February 26, 2016. Lawyers on Feb. 29 are expected to indict three former executives of Tokyo Electric Power Co. on charges of professional negligence resulting in death and injury in connection with the 2011 Fukushima nuclear disaster. &
3 ex-TEPCO execs to face indictment Monday
February 26, 2016. Three former top executives of Tokyo Electric Power Co. will be indicted Monday over the triple reactor meltdown at the company's Fukushima No. 1 nuclear power plant, court-appointed lawyers serving as prosecutors said Friday.
TEPCO discovers after 5 years that it could have quickly declared Fukushima plant meltdown
February 25, 2016. Nearly five years later, Tokyo Electric Power Co. said Feb. 24 that it has discovered a guideline in its operational manual that would have allowed it to announce meltdowns in the nuclear disaster in only days instead of the two months it actually took.
5 Years Later, the Fukushima Nuclear Disaster Site Continues to Spill Waste
March 1, 2016. The cleanup effort could take decades; meanwhile the amount of radioactive material the plant leaks grows
Five years on, Greenpeace assessing marine contamination off Fukushima.
Greenpeace is surveying waters near the Fukushima plant, dredging up sediment from the ocean floor to check both for radiation hot spots as well as places that are not contaminated &
TEPCO begins burning radiation-tainted work clothes at Fukushima plant
February 26, 2016. OKUMA, Fukushima Prefecture--Tokyo Electric Power Co. has started to incinerate the thousands of boxes of lightly contaminated waste, including clothing used by workers, at the Fukushima No. 1 nuclear power plant to reduce the amount of tainted waste on the site.
TEPCO: Step forward to contain radioactive water
The operator of the crippled Fukushima Daiichi nuclear plant says it will soon be able to stop the influx of radioactive water at some parts of the plant's reactor facility.
TEPCO nears 'deep freeze' of soil wall at Fukushima plant
February 21, 2016. Packed with bulky silver pipes and freezing equipment, Tokyo Electric Power Co.’s plant to freeze underground soil at the crippled Fukushima No. 1 nuclear power plant is ready to start chilling.
NRA commissioner suggests plan to remove all fuel debris at Fukushima plant may not be best option
FUKUSHIMA – A Nuclear Regulation Authority commissioner has suggested that removing all fuel debris from reactors at the meltdown-hit Fukushima No. 1 nuclear power plant may not be the best option.
For some Fukushima mothers, protecting children from radiation comes at heavy price
February 23, 2016. Three-and-a-half years after fleeing to central Japan, a mother received a package from her husband who had opted to remain at their home in Fukushima Prefecture despite the nuclear disaster.
Japan Olympic teams to train in nuclear clean-up zone
22 February 2016. Japan's Olympic football teams will train for the Tokyo 2020 Games at a complex currently being used as a base for thousands of workers cleaning up the crippled Fukushima nuclear plant.
Japan’s nuclear reactor restarts anger Minami Soma mayor
One video made him one of the most well-known faces of the Fukushima nuclear crisis.

No bliss in this ignorance: the great Fukushima nuclear cover-up
20th February 2016. The Japanese were kept in the dark from the start of the Fukushima disaster about high radiation levels and their dangers to health, writes Linda Pentz Gunter. In order to proclaim the Fukushima area 'safe', the Government increased exposure limits to twenty times the international norm. Soon, many Fukushima refugees will be forced to return home to endure damaging levels of radiation.

Takaama No.4 reactor restarted

The operator of a nuclear power plant in central Japan has put one of its reactors back online.


Storm brewing over nuclear energy programme
A storm that has been brewing over the Department of Energy’s nuclear energy programme and PetroSA could erupt, reports News24.
Joemat-Pettersson wants nuclear under IPP office
The 9 600 MW nuclear procurement programme should be run by the Independent Power Producer's (IPP) office, Minister of Energy Tina Joemat-Pettersson said on Tuesday.
Nuclear deal might push SA into junk
Things aren’t looking up for Africa’s second largest economy, with markets on edge awaiting the country’s budget speech, on February 24.


S. Korea rejects calls for nuclear armament, says its committed to nonproliferation
Feb 23, 2016. South Korea is firmly committed to nuclear nonproliferation.
That's according to Seoul's foreign ministry, which on Tuesday dismissed calls for the country to build its own nuclear arsenal to counter North Korea's nuclear and missile threats.


Screening truffles for radioactivity 30 years from Chernobyl
Swiss and German researchers have analysed Burgundy truffles collected in central Europe and found they contain only negligible amounts of radioactive caesium, being safe for consumption.


Trident rally is Britain's biggest anti-nuclear march in a generation
Thousands of protesters including Jeremy Corbyn and other party leaders gather in London for CND march and rally
UK new nuclear plan will fail without private investors, says Horizon chief
14 Feb 2016. Britain cannot just rely on state-backed enterprises like EDF and its Chinese partners to build a fleet of new nuclear reactors, Alan Raymant warns


Lawsuit targets Duke Energy Florida, FPL over higher rates for nuclear power projects
February 23, 2016. A class-action lawsuit was filed against Duke Energy Florida and Florida Power & Light Co. alleging the monopoly electricity providers force millions of Florida customers to pay unlawful charges in connection with their electricity rates to fund the companies' nuclear power plant projects, some of which have been abandoned.
Nuclear industry bemoans Clean Power Plan stay
February 23, 2016. WASHINGTON, D.C. — For an industry that said it was ignored by the Clean Power Plan, nuclear interests sure took it hard when the Supreme Court halted the rule earlier this month.
Entergy rebuffs latest NY plan to save FitzPatrick nuclear plant
February 23, 2016. SCRIBA, N.Y. – The state Public Service Commission said today it is working on plans to provide financial assistance to the FitzPatrick nuclear plant in a desperate attempt to keep the plant from shutting down.
Efficacy of compensation program for nuclear workers under scrutiny
Feb 22, 2016. ...Since Congress passed the Energy Employees Occupational Illness Compensation Program Act in 2000, the government has spent $12 billion in financial restitution for more than 100,000 workers whose onset of cancer, beryllium disease, neurological disorders and other ailments is a result of careers in the more than 300 nuclear facilities across the country. ...
But the program has come under scrutiny lately.  An investigation by the McClatchy DC news service found that fewer than half of the people who have applied for benefits have received them, and workers’ complaints are often suspended in the complex process of paperwork or court hearings, with some claims languishing in the system for up to 10 years.
Hanford contamination spread across public highway
February 21, 2016. The Environmental Protection Agency has called the uncontrolled spread of small amounts of radioactive waste at Hanford “alarming” after a Nov. 17 windstorm.

Whistleblowers Call for Inquiry into LANL Employee’s Death
Feb 2, 2016. Three Los Alamos National Lab (LANL) whistleblowers have called for a renewed investigation into the 2002 death of the lab’s former Deputy Director of Operations, Richard Burick. Steve Doran, Glenn Walp, and Chuck Montaño, along with Nuclear Watch New Mexico, have sent their appeal to the New Mexico District Attorney. They cite the Project On Government Oversight’s review of Montaño’s book, and additional interviews POGO conducted with Lab sources.
Nuclear waste dumped illegally in Ky.
Drilling wastes containing concentrated but naturally occurring radio active materials made their way into Kentucky, state officials confirmed on Thursday. &
Low-level radioactive waste illegally dumped in Estill landfill, state official says
Material generated from oil and gas drilling, not a nuclear plant
Some waste might have gone to a Greenup County landfill, too
Material might be dug up and removed but there are risks

Mia Pepper 

Conservation Council of Western Australia · 2 Delhi St, City West Lotteries House, West Perth, Western Australia 6005, Australia 
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Peach Bottom Annual Assessment Letter


Download ML16060A376

Susquehanna Annual Assessment Letter


Download ML16061A135

Three Mile Island Annual Assessment Letter



Download ML16054A774

ASLB to Hear Arguments on Nuclear Units under Construction in Georgia

Press Release II-16-004: ASLB to Hear Arguments on Nuclear Units under Construction in Georgia.

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03/22/2016 EXELON FLEET: Pre-application teleconference with Exelon to discuss a potential license amendment request regarding operating training standards

03/22/2016 EXELON FLEET: Pre-application teleconference with Exelon to discuss a potential license amendment request regarding operating training standards.

Download ML16061A137

Opening this Friday, March 4th, 6-9 PM. Fukushima disaster area report

It's the end of February and signs of spring are starting to appear.

I will be a part of the exhibition "Women in the Heights - Transitions" which is part of The Northern Manhattan Arts Alliance's celebration of Women’s History Month.

The opening and artist talk will be this Friday, March 4th, 6-9 PM.
My artist talk, "What is home? Where is home?" will refer to the issue of nuclear refugees.

Friday, March 4 - Tuesday, March 29
Gallery hours: Monday-Thursday 10 AM-4 PM
by appointment

Rio III Gallery
Sugar Hill Building, 898 St Nicholas Avenue @ 155th Street, 9th floor, New York NY 10032

March 11, 2016 is the 5th anniversary of the Fukushima nuclear accident. I wrote a report about my November 2015 visit to the Fukushima disaster area that I put on my blog in English.

I have attached the Japanese article that is an edited version of my blog report. This edited version in Japanese was published in NY Seikatsu, a Japanese language newspaper in New York.

I also have been exhibiting my prints "from key to key"
at Asian language school,  Hills Learning.
315 Madison Ave on 42nd St, Suite 900 New York  NY 10017
(Please call 212-784-0694 to verify access)

I hope to see you at the opening or in the near future.
Yasuyo Tanaka

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GreenCon at Dickinson College

The U.S. Green Building Council Is Pleased to Present:
Dickinson College, Holland Union Building, Carlisle PA
7:30am - 6:00pm March 17th
GreenCon is the region’s premier green building conference & expo and this year’s theme is resiliency. This is a great opportunity for both professionals and students to explore new avenues for a resilient future.  
Free admittance to all high school & college students!  
Students from all disciplines will benefit!
Environmental Studies    Sustainability Studies    Business/Marketing    Biology    Environmental Science    Community Development Business    Political Science    Architectural Design    Advocacy    Engineering    And More!

Keynote Speaker Alex Wilson, Founder of BuildingGreen, Inc. and President of the Resilient Design Institute
More than 30 companies in the exhibition hall
For more info, contact Eileen Reavey
Director, Central Pennsylvania Region Check out our new website!
U.S. Green Building Council
1519 N. 3rd St. Harrisburg, PA 17102
P: 717.903.9818  I  E:
Upcoming USGBC Central PA Events:
Earth Day Networking, April 21 at Tellus 360

PA DEP News Release : No Radioactive Contamination Detected Outside Beaver Falls Scrapyard

No Radioactive Contamination Detected Outside Beaver Falls Scrapyard

On February 23, 2016, the Pennsylvania Department of Environmental Protection (DEP) was notified that recycle scrap contaminated with radioactive material was shipped from a PSC Metals, Inc. facility in Beaver Falls, PA, to two facilities in Ohio. A radium-226 source of unknown origin was accidentally shredded with other materials, then shipped to processing facilities in Ohio.

A team from DEP’s Radiation Protection Program took extensive readings at the Beaver Falls scrapyard.  Elevated readings were found on one large metal shredder and on gloves used by two workers. DEP is performing additional testing to ensure that there was no skin contamination. Radium-226 can be harmful if ingested.

Read article

Urgent Organizational Decommissioning Sign-On

Citizens Awareness Network
Nuclear Information and Resource Service
U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001
ATTN: Rulemakings and Adjudications Staff

Comments on Nuclear Regulatory Commission Request Advanced Notice of Proposed Rulemaking Regarding Regulatory Improvements for Decommissioning Power Reactors

Jointly Submitted by Citizens Awareness Network and Nuclear Information and Resource Service

The following are comments jointly submitted by Citizens Awareness Network and Nuclear Information and Resource Service, in response to the Draft Regulatory Guide Docket ID NRC-2015-0070 request for comments on the advanced notice of proposed rulemaking regarding decommissioning of nuclear power reactors, published November 19, 2015. A hard copy will follow in the mail.

NRC’s attempt to streamline the decommissioning process instituted in the wake of the Yankee Rowe decommissioning and the Appellate Court Decision in CAN v NRC undermines the ability for the public or the state to participate in matters that vitally affect them. It also undercuts the Agency’s ability to effectively regulate the cleanup of contaminated sites. The First Circuit Appellate Court found the decommissioning of Yankee Rowe illegal and in violation of the National Environmental Policy Act, the Administrative Procedures Act and the Atomic Energy Act. NRC’s response to the Court’s reprimand was to codify its actions in Rowe and effectively deregulate decommissioning. The agency’s own Inspector General’s Report, NRC at a Crossroads, underscored the radical shift that NRC proposed and codified in 1996 (61 FR39278; July 29, 1996).

NRC is now proposing another radical shift in policy and regulation. Its decision to focus on the vulnerability of reactor fuel pools and dry cask storage as the sole priority for agency regulation of decommissioning abdicates its responsibility to impacted communities and states. The management and security of high-level radioactive waste is not formally part of the decommissioning process, it is covered by distinct and separate regulations. While the transfer of irradiated fuel from spent fuel pools to dry-cask storage facilities is necessary to complete decommissioning, license termination for the reactor ownership license may proceed separately under decommissioning, converting to a high-level waste storage license for the remaining dry- cask storage facility. This separation of decommissioning and high-level waste management is also evident in the NRC’s decommissioning funding assurance regulation, which does not include high-level waste costs in the calculation of minimum decommissioning funding assurance requirements.

NRC’s assertion in the Advance Notice of Proposed Rulemaking that the purpose of NRC rulemaking in regard to decommissioning is to manage the level of “radiological risk compared to operating reactors” is completely and utterly misinformed. The purpose of decommissioning is to facilitate the safe dismantlement of the nuclear reactor facilities and remediation of the site to permit its release to unrestricted use by the public, which entails reduction of risk to the public from long-term exposure to radioactive materials produced and deposited on the site as a result of the licensed activities that took place there. The license termination step, which concludes the decommissioning process, is to ensure that licensees are held accountable for satisfying the objectives of radiological decommissioning and site remediation and the promises made to reactor communities when the facilities were sited and licensed by NRC. The purpose of radiological risk reduction from irradiated fuel storage is covered by high-level waste regulations.

The intent suggested in the ANPR to scale back NRC oversight and involvement in the decommissioning process forecasts an abdication of regulatory authority and negligence toward the agency’s mandate to protect the public health and safety. To the extent that the regulatory analysis presented in the ANPR will structure the NRC’s proposed revisions to decommissioning regulations, it must be abandoned and a new course set. That course must be to address the proven experience and emerging problems confronting the protection of the public health and safety and achievement of the aforementioned purposes of decommissioning.

The primary focus of decommissioning must remain site remediation and restoration. Spent fuel management is a separate regulatory concern; it should not be solved by relegating decommissioning ratepayer subsidization of interim solution for HLW. By determining that cleanup of radiologically contaminated sites poses no risk to the public, NRC’s attempts to justify this radical rewriting of its rules. This is unacceptable.  Again, risk was not the issue in decommissioning, site remediation and license termination were. The comments provided below are directed toward revising the decommissioning regulations for those purposes.


Decommissioning trust funds for reactor cleanup are notoriously underfunded. The NRC permitsnuclear corporations to seriously under-fund their decommissioning funds with the rationale that, over time and with the ability for shuttered reactors to remain in SAFSTOR for up to 60 years, the funds required for cleanup will accumulate eventually. In addition, under utility owned nuclear facilities, utilities could request rate increases from state public service entities to cover any shortfalls in the fund.  This was certainly the case at Yankee Rowe and Connecticut Yankee. These captured ratepayers covered the substantial shortfalls for inadequate and incompetent financial planning. With NRC’s approval of merchant fleets of nuclear reactors, no captive ratebase exists to subsidize inadequate planning by licensees; contaminated sites can languish for indeterminate periods of time with no surety that the corporation responsible for cleanup will exist in 60 years. This undermines the impacted community as well as the states that remain in part responsible to represent ratepayers as well as state interests.


The decommissioning funding assurance regulation (10 CFR Part 50.75) was established to ensure licensees possess the resources for the cleanup of radiological contamination at reactor sites. Its express purpose is to permit the site to be released for unrestricted use (if possible) after cleanup is completed. However, NRC has permitted licensees, through an exemption process, to substantially undermine the financial viability of the trust funds by permitting their use for non- radiological purposes. For example Entergy Nuclear Vermont Yankee, LLC (ENVY), has advanced a series of propositions for the use of Vermont Yankee’s decommissioning fund that have nothing to do with radiological cleanup. However, these appropriations have everything to do with Entergy’s corporate structure, the licensee’s financial vulnerability and its lack of adequate operational funds. With NRC approval, Entergy intends to use decommissioning funds to pay its $600,000 in local taxes, its legal as well as lobbying expenses, its costs for fuel transfer from the fuel pool to dry cask storage , as well as for guarding the high level waste installation through the 2050’s.  Permitting these withdrawals is unacceptable; it seriously undermines the fund and substantially delays radiological cleanup. NRC should institute a process to hold parent companies accountable for the financial shortfalls of their LLCs.

NRC’s regulatory posture toward the use of decommissioning funds undermines state’s interests in ensuring a timely, safe, and effective decommissioning, and creates a massive subsidy to the industry at the expense of taxpayers and utility ratepayers. States permitted utilities to charge their customers for the cost of decommissioning trust fund contributions because those ratepayers benefited from the power generated by nuclear reactors. Now, the NRC is effectively allowing licensees to profiteer from a failed nuclear waste policy, on the backs of ratepayers and taxpayers: that is, the inability to implement a solution for its high level waste problem through the establishment of a nuclear waste dump by 1998, as required by the Nuclear Waste Policy Act. By granting exemptions from decommissioning trust fund regulations, NRC is now permitting nuclear reactor licensees with inadequate financial resources to raid the decommissioning fund for not just the establishment of dry cask storage, but, even more significantly, for the guarding of the waste on site.

Through suing DOE for this failure under the Nuclear Waste Policy Act, the industry has been able to win settlements reimbursing the corporations for the transfer of irradiated fuel from spent fuel pools to dry-cask storage (with settlements amounting to about 80% of the licensees’ claimed expenses). Despite permitting licensees exemptions from decommissioning trust fund regulations in order to access the trust funds for fuel transfer expenses, NRC has not required licensees to reimburse the trust funds with the settlement proceeds. This practice constitutes a massive misappropriation of decommissioning funds by allowing licensees’ parent companies to profit from the decommissioning funds. More importantly, it compromises public health and safety by justifying delays in the conduct of decommissioning and site remediation activities for potentially decades (through licensees’ exercise of the SAFSTOR option), until trust funds have accumulated sufficient value to cover radiological decommissioning costs.

In addition, high-level waste lawsuit settlements will not cover the escalating costs of guarding spent fuel storage installations, which could carry on indefinitely, as recognized by the NRC’s recently promulgated continued storage rule. NRC’s practice of granting licensees exemptions to access trust funds for that and other non-decommissioning purposes – such as local property taxes – exacerbates the risks to public health and safety and increases the subsidy to licensees, their parent companies and shareholders at states’ expense. It will not only further delay decommissioning and site remediation, but runs the risk of depleting decommissioning funds to the point that decommissioning cannot be completed with the available trust fund balances. NRC has not adequately addressed the issue of parent company liability for decommissioning, site remediation, and, ultimately, license termination under new corporate ownership structures that prevail today in the use of limited liability corporations (LLCs) as the sole possessors of the ownership licenses.

Under these circumstances, the existing regulations and NRC’s current regulatory practices could well result in financial liability for decommissioning falling to ratepayers and/or taxpayers to subsidize nuclear licensees’ lack of sufficient financial resources to protect and remediate their own sites, with parent companies protected from ultimate liability through the LLC ownership structure. Instead, NRC should both prohibit the use of decommissioning funds for non- decommissioning purposes and require parent companies to serve as co-licensees. In addition, NRC should require licensees to establish separate or auxiliary funds for other regulated activities, including the storage and management of high-level waste. Should the federal government implement a long-term management solution before such funds were fully expended, excess monies could be returned to the licensee.


Decommissioning should be reclassified as a Major Federal Action requiring NEPA compliance and the participation of the EPA in decommissioning. Cleaning up highly contaminated sites requires significant oversight. It should not be driven by licensees or their lack of adequate funding. The First Circuit Appellate Court justices opined in CAN v NRC that decommissioning is a major federal action and requires NEPA compliance. “An agency cannot skirt NEPA or other statutory commands by exempting a licensee from compulsory compliance, and then simply labeling its decision “mere oversight” rather than a major federal action. To do so is manifestly arbitrary and capricious.” NEPA compliance was required and mandated by the court for decommissioning. Doing so would reinstate the use of NRC resident inspectors and increase NRC oversight and public participation. It would reinstate EPA oversight beyond ground water contamination to address the significant chemical contamination at decommissioning sites. It could also support the requirement for an Emergency Planning Zone (EPZ) until the high level nuclear waste is transferred from high-density pool storage and secured in dry cask storage.

It is essential for NRC to define decommissioning as a major federal action. As the Appellate Court opined “… it is undisputed that decommissioning is an action which, even under the Commission’s new policy, requires NEPA compliance 10 C.F.R.  51.95(b.).” The Agency’s choice to streamline the process for licensees and deregulate NRC requirements abdicated the agency’s responsibility to protect the health and safety of the workers, the public, the environment, and also undermines citizen due process.


NRC’s radical 1996 revision of the decommissioning regulation eviscerated the hearing rights of the public, as well as states. Public meetings do not constitute the hearing rights required by the Atomic Energy Act and affirmed in CAN v. NRC.  Adjudicatory hearings offer citizens the right to cross examination and discovery. A public meeting does not afford citizens the level of institutional accountability necessary given the dangers of enviro-toxic contamination inherent in the cessation of reactor operations. Informational meetings, as experienced at Yankee-Rowe, Connecticut Yankee and Vermont Yankee,  do not effectively address the concerns of local residents since the local community -- and,  for that matter, states -- have no power to effect change in the licensee’s choices. In CAN v. NRC, both the Federal District Court and the Appellate Court chastised the agency for this approach. If the community has concerns, and there is no regulatory recourse save one "meeting" with NRC, the Commission will, in fact, create greater polarization between the community and the regulator. This can lead to intensified mistrust of the agency and further costly legal battles as is seen in the decommissioning of Vermont Yankee.  Advisory boards, such as Vermont’s Community Advisory Panel and similar bodies established in other decommissioning reactor communities, do not take the place of hearings.

Under the 1996 revision to the decommissioning regulations, the NRC also eliminated the requirement that licensees submit a decommissioning plan. Instead, licensees are only required to submit a Post-Shutdown Decommissioning Activities Report (PSDAR) within two years of final shutdown. The PSDAR is a brief document, lacking any meaningful detail as to the methodology and site-specific plans, essentially conveying that the licensee will figure it out as decommissioning proceeds. This fundamental change has eliminated any meaningful level of transparency and accountability for the conduct of decommissioning, allowing the licensee to proceed in relative secrecy and without NRC oversight.

The decommissioning plan must be a thorough guide and road map for the cleanup process; it is an instrument to hold a licensee accountable for the cleanup commitments it establishes in the plan. A 30 page narrative or report (PSDAR) identifying the licensee’s actions does not qualify as a plan and does not establish verifiable licensee commitments. The rulemaking must reinstitute the requirement that licensees submit a complete, thorough, and substantive decommissioning plan; and that NRC review and approve the plan, and oversee its implementation.


Existing decommissioning rules permit licensees to select among three methods for decommissioning at their sole discretion and without guidance as to the particular hazards and considerations they may pose to worker and public health and safety. DECON, or rapid dismantlement, involves dismantling reactor facilities and disposing of radioactive waste within just a few years after closure, while ambient radiation levels are still quite high. This has resulted in occupational safety hazards and contamination of workers; releases of radiation into the environment; and higher levels of radioactivity being deposited in radioactive waste dumps, as well as higher disposal costs.

SAFSTOR presents increasingly problematic outcomes. Under SAFSTOR, the licensee may exercise its discretion to defer decommissioning for an indeterminate period of time, so long as it is completed with 60 years from the date of closure. Licensees operating reactors in states with merchant power markets, where the licensee is not a utility company and has no access to rate making to pay for the cost of decommissioning, have opted for SAFSTOR as their decommissioning method of choice. It appears this is the case for two reasons: they have not continued to invest in the decommissioning trust funds they acquired along with the reactors, and they are seeking to defer liability for decommissioning fund shortfalls indefinitely, as well as to take advantage of NRC exemptions for use of the decommissioning fund. In addition, by delaying decommissioning for sixty years, it is possible that the licensee or its parent company may have declared bankruptcy or no longer exist, complicating NRC enforcement of the license.

The lenient use of SAFSTOR makes it possible for radioactive contamination onsite to spread unchecked, as well as to complicate the eventual dismantlement of the reactor facilities, due to structural degradation, corrosion, and animal infestation of the facilities. Examination of licensees decommissioning trust fund status reports, which include tables showing annual decommissioning trust fund projections out to the projected license termination dates, show that SAFSTOR is typically the most expensive decommissioning method as expenditures for mothballing the site accumulate over decades. The use of SAFSTOR must be justified and require selection of the earliest possible decommissioning date. Along with our above recommendations on decommissioning funding assurance and exemptions for use of the decommissioning fund, this would mitigate some of the worst outcomes that are possible under present regulations.

ENTOMB is only appropriate under very specific circumstances under which reactor facilities are too contaminated to be safely dismantled and/or disposed of, for example, reactors that have had major accidents, such as Chernobyl. The possibility that ENTOMB could be utilized for any purpose other than as an option of last resort is unacceptable.

NRC should encourage licensees to select the most protective decommissioning method possible by promulgating a fourth option. This method would balance the risks of DECON and SAFTSTOR described above, following one of the most successful reactor decommissionings to date: the Rancho Seco reactor in California. Currently, licensees are permitted to choose a combination of DECON and SAFSTOR, dismantling and decontaminating some parts of the reactor site immediately and postponing decommissioning of others until later.

NRC should formalize a fourth method that establishes best practices for achieving the objectives of decommissioning in a timely manner while minimizing risk to workers and the public. This method would involve thorough planning of decommissioning activities while attending to the most immediate risks first (e.g., eliminating high-density storage of irradiated fuel in spent fuel pools). Such an approach would also ensure the retention of the skilled workforce’s training and institutional knowledge, and it would enable decommissioning and site remediation to be completed in a reasonable period of time. For instance, transfer of irradiated fuel from high-density pool storage could occur in the first five to seven years, while monitoring, site surveys and decommissioning planning are conducted. Dismantlement and decontamination of the reactor facilities could take place beginning afterward, reducing ambient radioactivity levels before major dismantlement and decontamination activities start, thereby reducing the risk to workers, the public, and the environment. And site remediation could be completed within twenty to twenty-five years of closure of the reactor, permitting license termination in a reasonable period of time.

This decommissioning option could be labeled Planned Decommissioning and Site Remediation (PDSR). Rancho Seco’s owner, the Sacramento Municipal Utility District, was able to complete decommissioning within about twenty years, even though the decommissioning trust fund was underfunded at the time it closed the reactor (1989). By approaching decommissioning in roughly the fashion outlined above, SMUD was able to accumulate funds for the most expensive parts of decommissioning, while retaining a comparatively large percentage of the pre-existing workforce.



The outcome of decommissioning ultimately has the greatest impact on states and local communities. They have a direct and long-term stake in the issues most germane to the process, and they also tend to have oversight of overlapping regulatory issues and standards that are outside of NRC’s jurisdiction but which impact decommissioning activities, such as remediation of non-radiological pollution (e.g., toxic chemicals like PCBs). Certain reactor sites, like Yankee-Rowe, were able to complete radiological decommissioning to NRC’s standards, but have severe chemical contamination problems that have made it impossible for the sites to be released for unrestricted use. NRC would retain authority over certifying license termination, but permitting states to exercise agreement state authority over the rest of the process, and to promulgate their own rules per their agreement state authority, would conserve NRC resources while providing states and the public a beneficial and appropriate role in the process.


It is essential that the community in the effluent pathway of reactors as well as states that have oversight responsibilities, including advocacy for ratepayers, have the opportunity to participate in pollution reduction and prevention during decommissioning. This participation must be meaningful. The passive community participation in which limited information is fed to citizens to allay their fears is ineffective. Holding a meeting in a community to “inform” them of decommissioning is inadequate. The Appellate Court rejected this approach in the Yankee-Rowe case. A process must evolve which is responsive to the concerns of affected citizens who will continue to bear the burdens of long term exposure to low-level radiation and contamination. Citizens must have a substantive role in decommissioning in order to clarify, negotiate and protect their community’s interests and to satisfy the requirements of a constitutional democracy.

Communities should be given the opportunity to participate in decommissioning from its onset. Therefore, we propose that Site-specific Advisory Boards be offered to reactor communities as a formal mechanism of community participation during decommissioning, since the process of site clean-up could span decades if not lifetimes. These boards must be independently convened in order to be effective. The Advisory Board would meet regularly to give meaningful input into decisions concerning health and safety, pollution prevention and reduction. The boards would function to educate the community regarding the impacts of the technology that exist in their neighborhood. They should include diverse interests such as local government, public interest groups, representatives of towns in the effluent pathway (including representatives from adjacent states), tribal governments, reactor worker representatives, and Federal and State regulators such as the NRC, public health and environmental departments, etc. An ecology of democracy must develop for local residents, scientists, technologists, industry, and regulators to work together to solve the contamination problems inherent in the nuclear fuel cycle. Costs for expert consultation should be borne by the licensee, either by allocation from NRC or, in the case of agreement state regulation as recommended herein, state regulatory authorities with oversight of the decommissioning process.



NRC currently provides no meaningful oversight and enforcement of decommissioning activities. There are no resident inspection staff after permanent shutdown of the reactor, and there are no regular inspections during the decommissioning process. With no meaningful public involvement, no hearing rights, and no detailed planning required for decommissioning, the lack of NRC oversight means licensee compliance with regulations is impossible to verify and enforce at all, much less on a timely basis. NRC must provide for a meaningful oversight process for decommissioning, including dedicated inspection staff with relevant specialization and expertise, regular inspections and reporting, substantive public information and engagement, and timely enforcement mechanisms.


NRC is required under federal law to collect fees from its licensees (and license applicants) in amounts that total 90% of the agency’s annual budget. Each year, NRC proposes a revised fee schedule to Congress and, upon approval, updates 10 CFR Part 171 of its regulations. It has been NRC practice to charge vastly reduced fees to reactor licensees during decommissioning, and over the last few years, the gap between operating and decommissioning reactor license fees has widened significantly. In 2013, operating reactor license fee was $4,390,000; the decommissioning reactor license fee was only $231,000, or nineteen times less. In 2015, the operating reactor license fee had risen nearly 15%, to $5,030,000, but the decommissioning reactor license fee had actually decreased By 3.5%, to $223,000.

This clearly reflects the NRC’s oversight and enforcement posture toward decommissioning. That must change not only to better align the agencies priorities toward providing meaningful oversight of decommissioning activities for the reasons detailed above, but also to correct a conflict of interest in the lopsided fee structure. In effect, NRC has provided a perverse incentive both to devalue public health and safety issues involved in decommissioning and site remediation and to enforce safety standards for operating reactors less stringently.

On the one hand, by charging such small fees for decommissioning reactors, NRC cannot justify devoting staff and technical resources to decommissioning-specific issues that could better inform its understanding of the needs and priorities for regulation and enforcement. And on the other hand, because the agency takes such a significant hit to its budget with each reactor that closes, it could inculcate a culture within the agency that views enforcement of safety regulations as a threat to the agency’s budget and the job security of NRC staff.

This conflict must not be allowed to continue, and NRC must ensure that it has adequate resources to provide greater oversight and enforcement of decommissioning, particularly as more reactors are closing and decommissioning becomes a more prevalent public health and safety concern.



Deb Katz
Executive Director
Citizens Awareness Network
P.O. Box 83
Shelburne Falls, MA  01370

Timothy Judson
Executive Director
Nuclear Information and Resource Service
6930 Carroll Ave., Suite 340
Takoma Park, MD  20912

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