Established in 1982, the Nuclear Age Peace Foundation is a non-profit, non-partisan, education and advocacy organization that initiates and supports efforts to eliminate nuclear threats to humanity. With headquarters in California, the Foundation has a membership of thousands individuals across the United States, including in Nevada.

On behalf of the Nuclear Age Peace Foundation and our members, I am here today to express our deep concern over the Environmental Protection Agency’s revised radiation protection standard for the Yucca Mountain high-level radioactive waste dump in Nevada. We believe this revised radiation protection standard will fall far short of protecting public health and that it even disregards the agency’s own previous recommendations. If approved, this standard will ignore the scientific consensus on the health impact of radiation, as well as the many unresolved problems surrounding radioactive waste. It will set a terrible precedent; lowering the bar for radiation protection across the country.

The Yucca Mountain project is a distinct danger to defenseless citizens – not just to this generation, but to thousands of generations to come who will be affected by this decision. In July 2004, a DC Circuit Court of Appeals decision found EPA’s previous standard – a 15 millirem per year radiation exposure limit for 10,000 years – to be illegal. According to the ruling, the standard EPA sets for Yucca Mountain must be consistent with a National Academy of Science (NAS) study on the subject, which recommended that the standard extend through the time of highest risk to the public, known as the “peak dose.” The Department of Energy estimates peak dose at several hundred thousand years.

The EPA’s recently revised standard, however, fails to comply with the court ruling and the intent of the NAS recommendations. Instead of extending the 15 millirem per year limit through the time of peak risk, the EPA has proposed a two part standard – 15 millirem per year for 10,000 years, and then a 350 millirem per year standard thereafter (up to a million years).

Such a standard is not scientifically justified, and would perhaps be the least protective radiation standard in the world. No other US or international radiation protection standard permits a dose of 350 millirems per year to individuals. In fact, EPA’s proposed standard is not even consistent with the agency’s own previous recommendations.

Yucca Mountain is located on Native American land, belonging to the Western Shoshone by the treaty of Ruby Valley. The Western Shoshone National Council has declared this land a nuclear free zone and demanded an end to nuclear testing and the dumping of nuclear wastes on their land. We support the claims of the Western Shoshone to the sovereignty of their land, which they hold as sacred, and we believe that the revised radiation standard is a form of environmental racism that will disproportionately harm the lands and health of the Western Shoshone people.

We are also concerned that Yucca Mountain sits above the only source of drinking water for the residents of Amargosa Valley. The aquifer below Yucca Mountain provides water to Nevada’s largest dairy farm, which supplies milk to some 30 million people on the west coast. Another casualty of EPA’s proposed rule is the Safe Drinking Water Act standard limiting radiation in drinking water to 4 millirem per year, which EPA would only enforce for the first10,000 years, but would then replace with the 350 millirem year all pathway exposure limit. Water is a precious resource, which will require more, not less, protection as time goes on. Yucca’s radioactive wastes will leak into the underlying drinking water aquifer, which will become the primary pathway for harmful doses to people downstream. The Safe Drinking Water Act standard should be applied to protect Yucca’s aquifer and the people downstream for as long as the high-level radioactive wastes remain hazardous, hundreds of thousands of years into the future.

Yucca Mountain is also directly above an active magma pocket and is the third most seismically active area in the United States. In the past 25 years alone, over 600 earthquakes of 2.5 or greater on the Richter Scale have struck within 50 miles of Yucca Mountain. In 1992, a 5.6 quake cracked walls, shattered windows, and caused some one million dollars in damage to the Department of Energy (DoE) field office studying the site. On July 14, 2002, an earthquake registered a magnitude of 4.4 on the Richter Scale. It defies reason to expect that radioactive wastes will sit for tens of thousands of years undisturbed by unpredictable nature, or by human or technological errors in the design of the containment structure itself.

The problem of what to do with high-level radioactive wastes warrants additional consideration and resources, including investigation of alternatives to Yucca Mountain. Instead of setting a new and very dangerous precedent for the storage of radioactive waste throughout the country in order to simply satisfy political pressures to license Yucca Mountain, the Environmental Protection Agency should fulfill its mission to protect human health and the environment. We ask you to withdraw this standard immediately, and propose a standard that is truly protective of public health and the environment for this generation and generations to come.