Although the 20-day public comment period ended on August 18, 2010, the National Academy of Sciences continues to accept comments on the composition of the provisional committee that will study the feasibility of uranium mining in Virginia. The deadline has been extended until the first committee meeting, which is yet to be scheduled. The comment period was extended in response to 120 requests for extenstion of time received by NAS from various public interest groups and concerned citizens.
You can sign on the comments prepared by UraniumFree Virginia by sending your name and location to uraniumfreeVA@gmail.com or you can send separate comments on the provisional appointments directly to the study director Dr. David Feary at dfeary@nas.edu
Committee Membership Information
Project Title: Uranium Mining in Virginia
PIN: DELS-BESR-09-06
Major Unit: Division on Earth and Life Studies
Sub Unit: Board on Earth Sciences & Resources
Water Science and Technology Board
RSO: Feary, David
Subject/Focus Area: Earth Sciences
Committee Membership
Date Posted: 07/29/2010
Dr. Joaquin Ruiz - (Chair)
University of Arizona
JOAQUIN RUIZ is Executive Dean of the Colleges of Letters, Arts and Science, Dean of the College of Science, and a Professor of Geosciences at the University of Arizona. Prior to being appointed as Dean of the College of Science, Dr. Ruiz served as the Head of the University of Arizona’s Department of Geosciences from 1995 to 2000. Dr. Ruiz is an expert in radiogenic isotopes applied to the study of regional tectonics, origin of magmas, and hydrothermal ore deposits. He was elected to the Mexican Academy of Science in 2006. He has served as a member of the U.S. National Committee for the International Association for Volcanology and Chemistry of the Earth’s Interior; a member of the National Science Foundation’s Instrumentation Panel with the Division on Earth Sciences; and was a panel member of the Facilities Program and Centers for Excellence in Science and Technology Program with the Directorate of Education. Dr. Ruiz is a Fellow of the Geological Society of America and of the Society of Economic Geologists. He received a B.Sc. in Geology and a B.S. in Chemistry from the University of Miami and a M.S. and Ph.D. in Geology from the University of Michigan, Ann Arbor.
Dr. Corby G. Anderson
Colorado School of Mines
CORBY ANDERSON is the Harrison Western Professor of Metallurgical and Materials Engineering at the Colorado School of Mines. Dr. Anderson is an expert in the fields of mineral processing, waste minimization and recycling, has an extensive background in industrial-oriented research, and has more than 30 years of academic and applied experience in mining, chemical, and materials engineering. In 2008 he received the Milton Wadsworth Award from SME for his contributions to advance the field of chemical metallurgy. Dr. Anderson holds a Ph.D. in Mining Engineering - Metallurgy from the University of Idaho, as well as a Bachelors degree in Chemical Engineering and a Masters degree in Metallurgical Engineering.
Dr. Lawrence W. Barnthouse
LWB Environmental Services, Inc.
LAWRENCE W. BARNTHOUSE is the President and Principal Scientist of LWB Environmental Services, Inc. His consulting activities include 316(b) demonstrations for nuclear and non-nuclear power plants, Superfund ecological risk assessments, Natural Resource Damage Assessments, risk-based environmental restoration planning, and a variety of other projects involving close interactions with regulatory and resource management agencies. Dr. Barnthouse has authored or co-authored more than 90 publications relating to ecological risk assessment. He is a Fellow of the American Association for the Advancement of Science, Hazard/Risk Assessment Editor of the journal Environmental Toxicology and Chemistry, and Founding Editorial Board Member of the new journal Integrated Environmental Assessment and Management. He has served on the National Research Council Board of Environmental Studies and Toxicology and on several National Research Council committees, and was a member of the peer review panel for the U.S. Environmental Protection Agency’s Guidelines for Ecological Risk Assessment. Dr. Barnthouse holds a PhD in biology from the University of Chicago.
Dr. Scott C. Brooks
Oak Ridge National Laboratory
SCOTT C. BROOKS is Senior Scientist in the Environmental Sciences Division of Oak Ridge National Laboratory. Dr. Brooks’ research focuses on the biogeochemistry of advecting fluids in the subsurface and the geochemical factors influencing the fate and transport of solutes. He has conducted numerous experiments at the laboratory and field scale studying the fate and transformation of radionuclides in the environment. He has Ph.D. and M.S. degrees in Environmental Sciences from the University of Virginia.
Dr. Patricia A. Buffler
University of California, Berkeley
PATRICIA BUFFLER (IOM) is professor of epidemiology and holds the Kenneth and Marjorie Kaiser Chair in Cancer Epidemiology in the School of Public Health at University of California, Berkeley. Dr. Buffler’s research interests include the environmental causes of cancer, especially gene-environment interaction and childhood cancer, lung cancer, leukemia, brain cancer, and breast cancer; epidemiologic research methods; and the uses of epidemiologic data in health policy. She has served on numerous committees of the National Research Council, including the Committee on Health Risks from Exposure to Low Levels of Ionizing Radiation, and Committee on Emerging Issues and Data on Environmental Contaminants. Dr. Buffler was elected to the Institute of Medicine in 1994. She received a Ph.D. in epidemiology from the University of California, Berkeley.
Dr. Michel Cuney
CNRS
MICHEL CUNEY is director of the research team, Genesis and Management of Mineral Resources for the National Center for Scientific Research (CNRS) at the Henri Poincaré Universite in Nancy, France. He has worked mainly on the geochemistry of uranium in various geological environments since 1972. He has visited and/or worked on most major uranium deposits of the world, and has published about 180 scientific papers in this disciplinary area. Dr. Cuney is one of the world's experts on the genesis of uranium deposits and uranium geology, and he will provide invaluable insights concerning mining techniques that would be used to extract uranium from deposits in Virginia as well as the possible effects on the local environment. Dr. Cuney received his Docteur es Sciences (Ph.D.) degree from Henri Poincaré Universite.
Dr. Peter L. deFur
Environmental Stewardship Concepts
PETER L. DEFUR is President of Environmental Stewardship Concepts, LLC (ESC), an independent private consulting firm in Richmond, Virginia. He is also an affiliate Associate Professor at the Center for Environmental Studies, Virginia Commonwealth University where he conducts research on environmental health and ecological risk assessment. Dr. deFur has over thirty years’ experience providing technical services regarding the cleanup of contaminated sites to community organizations across the country. Dr. deFur received B.S. and M.S. degrees from the College of William and Mary, and a Ph.D. in biology from the University of Calgary.
Dr. Mary R. English
The University of Tennessee, Knoxville
MARY ENGLISH is a Senior Fellow at the Institute for a Secure and Sustainable Environment, The University of Tennessee in Knoxville. She is a social scientist who is familiar with the environmental effects of mining and related regulatory issues. Her work has focused on energy and environmental policy and has included research on mechanisms for involving stakeholders in public policy decisions, how "the community" should be defined within the context of community-based environmental efforts, information-gathering and analytic tools to improve environmental decision making, and guidance on conducting socioeconomic impact assessments. She previously served on the NRC Board on Radioactive Management as well as the NRC Board on Environmental Studies and Toxicology. Dr. English has a M.S. from the University of Massachusetts and a Ph.D. in Sociology from the University of Tennessee, Knoxville.
Dr. R. William Field
University of Iowa College of Public Health
R. WILLIAM FIELD is a Professor in the Department of Occupational and Environmental Health and in the Department of Epidemiology, University of Iowa College of Public Health. He also serves as Director of the Occupational Epidemiology Training Program, at the NIOSH-Heartland Center for Occupational Health and Safety, and Director of the Pulmonary Outcomes Cluster, NIEHS - Environmental Health Sciences Research Center (EHSRC). Dr. Field has been active in numerous national and international collaborative radiation-related epidemiolgic projects for many years and has served on the editorial boards of several national and international scientific journals.. His research interests fall into the broad categories of environmental epidemiology, occupational epidemiology, radioepidemiology, cancer epidemiology, immune-mediated disease epidemiology, health physics, biomonitoring, risk perception, and novel methods of retrospective exposure assessment. Dr. Field received his Ph.D. in preventive medicine and environmental health from the University of Iowa.
Dr. Jill Lipoti
New Jersey Department of Environmental Protection
JILL LIPOTI is Director of the Division of Environmental Safety and Health at the New Jersey Department of Environmental Protection. Prior to assuming this position, she was an Assistant Director with responsility for directing the state’s radiation protection programs. Dr. Lipoti also serves as adjunct assistant professor, University of Medicine and Dentistry of New Jersey - School of Public Health, Department of Environmental and Occupational Health, specializing in radiation exposure, and preparedness for chemical and radiological emergencies. She has provided advice to the International Atomic Energy Agency regarding radiation safety and security, and has served on the Radiation Advisory Committee of EPA’s Science Advisory Board. She has M.S. and Ph.D. degrees in environmental science from Rutgers, The State University of New Jersey.
Dr. Paul A. Locke
Johns Hopkins Bloomberg School of Public Health
PAUL A. LOCKE, an environmental health scientist and attorney, is an Associate Professor at the Johns Hopkins University Bloomberg School of Public Health in the Department of Environmental Health Sciences, Division of Toxicology. He holds an MPH from Yale University School of Medicine, a DrPH from the Johns Hopkins University Bloomberg School of Public Health and a JD degree from Vanderbilt University School of Law. Dr. Locke’s research and practice focus on how decision makers use environmental health science and toxicology in regulation and policy-making and how environmental health sciences influence the policy-making process. His areas of study include designing and evaluating radiation protection initiatives and radiation policies, especially in the areas of low dose radiation science, radon risk reduction, safe disposal of high level radioactive waste, and use of CT as a diagnostic screening tool. Dr. Locke directs the School’s Doctor of Public Health program in Environmental Health Sciences. Dr. Locke was a member of the National Academy of Sciences Nuclear and Radiation Studies Board from 2003 to 2009, and has served on five National Research Council committees. He is also a member of the editorial boards of Risk Analysis: An International Journal and the International Journal of Low Radiation and is on the Board of Directors of the NCRP (National Council on Radiation Protection and Measurements). He is admitted to practice law in the states of New York and New Jersey, the District of Columbia, the Southern District Court of New York and the United States Supreme Court.
Mr. Henry Schnell
Areva, Inc.
HENRY A. SCHNELL holds the position of Technical Authority (Senior Expert) in the Expertise & Technical Department, Mining Business Unit, with AREVA NC Inc., In his role as Technical Authority for uranium, he is responsible for review and support of existing operations and new projects world wide, and for final technical authorization of plant design and modifications. Mr. Schnell has 41 years of experience in management, plant operations, plant design, engineering, and research and development in mining and ore treatment, and 21 years of this has been specializing in uranium metallurgy, operations, and mining projects. He has a B.S. (Honours) degree from the University of Alberta, Edmonton and other extensive training in metallurgy and project management.
Dr. Jeffrey J. Wong
California Environmental Protection Agency
JEFFREY J. WONG is Deputy Director of the Science, Pollution Prevention and Technology Program for the California Department of Toxic Substances Control (DTSC) at the California EPA and serves as DTSC's Chief Scientist. This program's activities include environmental measurements, biological and exposure monitoring, toxicology and risk assessment, and green chemistry and pollution prevention. Before his current appointment Dr. Wong served as chief of DTSC's Human and Ecological Risk Division. He served by presidential appointment on the U.S. Nuclear Waste Technical Review Board from 1996 until 2002. Dr. Wong has served on several National Academies committees, including the Committee on Risk-Based Approaches for Disposition of Transuranic and High-Level Radioactive Waste, the Committee on Environmental Remediation at Naval Facilities, the Committee on Remedial Action Priorities for Hazardous Waste Sites and the Panel for Review of the DOE Environmental Restoration Priority System. Dr. Wong received his Ph.D. in pharmacology and toxicology from the University of California at Davis.
Monday, August 23, 2010
Wednesday, August 18, 2010
Comments on the Composition of the Uranium Mining Study Committee
August 18, 2010
Dr. David Feary
Study Director
Board on Earth Sciences and Resources
Division on Earth and Life Studies
National Academy of Sciences
500 Fifth Street, NWWashington, DC 20001
Re: The Composition of Provisional Committee for the Study of
Uranium Mining in Virginia, DELS-BESR-09-06
Dear Dr. Feary:
We appreciate the opportunity to comment on the composition of the provisional study committee on uranium mining in Virginia, established to examine the scientific, technical, environmental, human health, safety, and regulatory aspects of uranium mining, milling, and processing as they relate to the Commonwealth of Virginia. The committee’s work is extraordinarily important, as the findings of the study will assist the Commonwealth in determining whether uranium mining, milling, and processing can be undertaken in a manner that safeguards the environment, natural and historic resources, agricultural lands, and the health and well-being of its citizens.
Proposed uranium mining has been a controversial issue in the Commonwealth of Virginia since late 1970s when the uranium mining deposits were first discovered. For years, this matter has been an issue of utmost concern for the communities that may potentially be affected by uranium mining. For these reasons, it is very important that this uranium mining study be performed by a well-balanced and objective panel of scientists and experts who are free of any obligations to entities that may either benefit or be disadvantaged by the findings of this study.
Unfortunately, it appears that several members of the provisional committee have conflicts of interest that could significantly impair their objectivity and further damage the credibility of this study in the eyes of the public. As more fully discussed below, we respectfully request that the Board on Earth Sciences and Resources (thereafter, BESR) conduct a review of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, and Dr. Michel Cuney for a potential conflict of interest, and remove Mr. Henry Schnell from the study committee due to an apparent conflict of interest.
It has been widely reported in the Virginia local press that the funding for this study is coming from Virginia Uranium, Inc., the company seeking to lift Virginia’s 1982 ban on uranium mining, and that the Virginia Center for Coal and Energy Research at the Virginia Polytechnic Institute and State University is serving as a mere conduit for funneling the study funds to the National Research Council. The Governing Board Executive Council of National Academies was apprised of this situation in an October 2, 2009 letter signed by over 30 concerned citizens. Because of the nature of the end source of funding, the study’s credibility is already being questioned by the public.
Under these circumstances, it is especially important that the study process be conducted in a manner ensuring transparency and an ample opportunity for public comment. Accordingly, we respectfully request that the BESR extend the comment period until August 30, 2010. Pursuant to Section 15(b) of the Federal Advisory Committee Act (thereafter, FACA), the National Academy of Sciences “shall … provide a reasonable opportunity for the public to comment on … appointments before they are made or… in the period immediately following the appointments.” While a 20-day comment period has been the National Academies’ long-standing practice, limiting it to 20 days is not required by law. In this particular case, given the controversial nature of the issue to be examined in the uranium mining study, and the fact that most of Virginia residents received either no notice or insufficient notice of the commencement of the comment period, the BESR should extend the public comment period until August 30, 2010 to allow all interested parties to comment on the composition of the provisional committee.
In addition, we urge the BESR to conduct public hearings to provide an open public forum for interested parties to participate in the study committee discussions in accordance with Section 15(b)(3) of FACA, and to promptly make available to the public a summary of any committee meetings and any materials provided to the study committee in compliance with Sections 15(b)(3)-(4). The general public should also be provided with a sufficient notice of at least thirty (30) days prior to the date of the public meeting and an opportunity to submit written comments on the public committee discussions.
We believe that public meetings should be conducted so as to include all the locations in the Commonwealth of Virginia that may potentially be affected by uranium mining. Historically, uranium companies have shown interest in uranium in Culpeper, Fauquier, Franklin, Floyd, Henry, Madison, Nelson, Orange, Patrick, and Pittsylvania Counties and leased mineral rights on approximately 50,000 acres in the 1980s. Downstream from these areas, there are counties and municipalities whose drinking water could be affected by uranium mill tailings. These include Brunswick, Fairfax, Halifax, Mecklenburg, Virginia Beach, Chesapeake, and others. If the uranium mining ban is lifted, we would likely see exploration for uranium in the black shale of Southwest Virginia, in crystalline granite throughout the Blue Ridge, and in sedimentary rock in the Coastal Plains, as well as further exploration in the Northern and Southern Piedmont. Conducting public meetings at multiple locations will ensure the utmost degree of transparency of the study process for such a controversial issue as uranium mining.
Potential Conflict of Interest
The National Academies have established policies and procedures for addressing potential conflicts of interest to be used by committees in the development of its reports. This policy states that “[i]t is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest. For this purpose, the term "conflict of interest" means any financial or other interest which conflicts with the service of the individual because it (1) could significantly impair the individual's objectivity or (2) could create an unfair competitive advantage for any person or organization. Except for those situations in which the institution determines that a conflict of interest is unavoidable and promptly and publicly discloses the conflict of interest, no individual can be appointed to serve (or continue to serve) on a committee of the institution used in the development of reports if the individual has a conflict of interest that is relevant to the functions to be performed.”
We wish to bring the following matters of concern to the attention of the National Academies and the BESR regarding employment, existing fiduciary duties, consulting services, and promotional activities of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, Dr. Michel Cuney, and Mr. Henry Schnell that to the best of our knowledge have not been publicly disclosed as potential conflicts of interest in regard to the uranium mining study.
Dr. Corby G. Anderson currently serves as s trustee for the Northwest Mining Association, a trade association, whose stated purpose is to represent and inform members on legislative, regulatory and technical issues, to support and advance the mineral resource and related industries, and to foster and promote economic opportunity. Among the members of the Northwest Mining Association are Denison Mines Corp., a publicly traded company operating three uranium mines and two uranium mills in North America, and Uranium One Inc., one of the world’s largest publicly traded uranium producers. As a trustee of this trade association, Dr. Anderson has a fiduciary duty to the association and its members to act in their best interests. Although the study is designed to examine the feasibility of uranium mining in the Commonwealth of Virginia, the outcome of this study, similar to all studies completed by the National Academies, will set precedent for the entire uranium mining industry here in the United States and possibly around the world. The study findings will serve as the basis for the Virginia General Assembly’s determination of whether to lift the 28-year ban on uranium mining. The Virginia General Assembly’s action on the uranium mining ban has a potential of impacting economic opportunities for many uranium mining companies, including the companies that are corporate members of the Northwest Mining Association.
In addition, to the best of our knowledge, Dr. Anderson routinely undertakes contracted projects for global industrial client projects, including serving as an expert witness in mining litigation. Under the National Academies’ Policy on Committee Composition and Balance and Conflicts of Interest, a consulting relationship, such as serving as an expert witness in litigation, constitutes a potential financial conflict of interest.
Furthermore, Anderson also serves on the Board of Directors of Phoenix Minerals, Inc. and is President and COO of Getty Copper Inc. Both are publicly traded mining companies. In connection with this, we respectfully request that BESR investigate whether any of the two companies currently operate a uranium mine or mill and whether they presently have plans to mine or mill uranium.
Dr. Lawrence W. Barnthouse is an owner of LWB Environmental Services, Inc., a consulting company that provides ecological risk assessments and risk-based environmental restoration planning. Among Dr. Barnthouse’s clients are large law firms that represent clients from all over the country in environmental litigation and environmental regulatory proceedings. This appears to indicate that Dr. Barthhouse serves as an expert witness for those law firms and their clients on the issues that may be the subject matter of the uranium mining study. The National Academies’ policy on conflicts of interest provides that serving as an expert witness is a type of consulting relationship that may constitute a financial interest. Accordingly, we request that BESR further investigate Dr. Barnthouse for a conflict of interest based on the nature of the consulting services he provides to his clients. BESR’s review should address whether Dr. Barnthouse serves as an expert witness on issues that will be examined in the uranium mining study and whether he provides expert testimony on behalf of uranium mining companies, regardless of whether they are his direct clients or clients of his clients.
Dr. Michael Cuney’s industry consultation includes work for major uranium mining companies, such as Areva and Uranor Inc. The findings of the uranium mining study will determine future economic opportunities for Dr. Cuney’s corporate clients in the Commonwealth of Virginia. Thus, Dr. Cuney’s consulting relationship with uranium mining companies constitutes a potential conflict of interest and warrants review by BESR.
In addition, as stated in Dr. Cuney’s biography, he has visited and/or worked on most major uranium deposits of the world. BESR should investigate in what capacity Dr. Cuney traveled to all those mining sites, who funded his trips and whose interests he represented during those trips and to which companies he provided the services in connection with the trips, and whether these companies continue to use his services.
Furthermore, Dr. Cuney participates in numerous international conferences. In fact, he was a speaker at the Global Uranium International Conference held in Colorado in May 2009, where the Coles Hill, VA deposit was discussed at length. We, therefore, request that BESR require Dr. Cuney to disclose whether he received any honorarium or travel expense reimbursements for his participation in these activities and any other uranium mining conferences and who sponsored his trips to such conferences.
Mr. Henry Schnell has an apparent conflict of interest based on his employment. Mr. Schnell holds a senior position in the Mining Business Unit with Areva NC Inc., a multinational company that owns and operates, either directly or through its subsidiaries, uranium mines in many parts of the world, including North America. Specifically, Areva’s subsidiary Pathfinder Mines Corporation operates large uranium mines in Wyoming that are currently undergoing reclamation. As stated above, the study’s finding will set precedent for the entire uranium mining industry and will have a potential to affect economic opportunities for many uranium mining companies, including Mr. Schnell’s employer, Areva.
In addition, we would like to bring to BESR’s attention the fact that Areva Inc. is actively involved in promoting uranium mining in Virginia. Virginia Energy Independence Alliance (thereafter, VEIA), whose two out of three corporate members are Areva Inc. and Virginia Uranium, Inc., has been very outspoken and pro-active in its campaign to support uranium mining in the Commonwealth. The VEIA Chairman Ray Ganthner has just retired from his position of Senior Vice President with Areva. Most recently Mr. Ganthner appeared on behalf of VEIA at the June 22, 2010 public hearing conducted by the Virginia Coal and Energy Commission on uranium mining and spoke publicly on behalf of VEIA in favor of uranium mining. Because VEIA at this time has only three corporate members, one of which is Areva Inc., it is reasonable to conclude that when the VEIA Chairman speaks on the subject of uranium mining, it represents Areva’s views and promotes Areva’s best interests.
This demonstrates that Mr. Schnell’s employer Areva may directly benefit or may be disadvantaged by the findings of the uranium mining study. Because of his employment and his employer’s particular interest in uranium mining in Virginia, Mr. Schnell’s objectivity may be significantly comprised. Mr. Schnell’s participation in this study may create an unfair competitive advantage for Areva. Accordingly, we request that Mr. Schnell be removed from the study committee due to his apparent conflict of interest.
Balance of the Study Committee
Under the Statement of Task for the uranium mining study, the study committee is called upon to examine 12 questions covering a wide range of areas from legal framework to public health and safety to mining methods to reclamation and waste management to cultural issues to geology, climate and water management, etc. Despite the fact that the scope of the uranium mining study is vast and complex, the study committee is comprised of only 13 experts. It appears that some of the issues included in the study will be examined by only one expert. A committee that has only one expert per issue cannot be characterized as balanced because the study process will fail to ensure peer review on one or more issues. For this reason, we believe that the committee membership must be expanded to include more experts, especially in the areas highlighted below.
The first item of the Statement of Task directs the study committee to “assess the potential short- and long-term occupational and public health … considerations … including the potential human health risks.” Item 4 directs to “analyze the impact of uranium mining, milling, processing, and reclamation operations on public health.” Comprehensive examination of items 1 and 4 of the Statement of Task requires an expert in occupational and public health, as well as a medical doctor. The provisional committee currently includes public and occupational health experts and epidemiologists but no medical doctor. We, therefore, request that the BESR appoint an expert with the medical doctor degree to the study committee.
Pursuant to item 4 of the Statement of Task, the study committee is to “analyze the impact of uranium mining, milling, processing, and reclamation operations … at sites with comparable .. hydrologic … characteristics to those found in the Commonwealth.” In addition, item 9 directs the study committee to “identify the issues that may need to be considered regarding the quality and quantity of groundwater and surface water… As relevant, water and waste management … may also be considered.” The potential impact of uranium mining on water supply has been of utmost concern for the communities where uranium mines may be developed and to the communities, like Fairfax and Halifax Counties and the City of Virginia Beach, and all the communities in the Roanoke River Basin including those in North Carolina whose sources of drinking water are located in areas where uranium mining is likely to occur should the uranium mining ban is lifted. For this reason, we respectfully request BESR to ensure that the study committee includes a sufficient number of experts with the expertise in hydrology and water-related issues.
Item 5 of the Statement of Task directs the study committee to “review the … cultural settings … in the Commonwealth of Virginia.” A comprehensive analysis of the cultural settings requires an expertise in environmental justice. Unfortunately, it is not apparent from the information posted on the credentials of the provisional committee members whether the committee includes experts in environmental justice. Because uranium mining is likely to affect many communities with relatively low socioeconomic status and very little influence over legislative decisions and limited access to the legal system, it is very important that the issue of environmental justice be examined thoroughly in the study. To this end, the study committee should be expanded to include at least two experts in environmental justice with experience of addressing these issues in the communities affected by uranium mining. We would welcome an opportunity to provide nominations for all above-mentioned areas of expertise.
In addition, it appears that the majority of questions under the Statement of Task require global expertise in uranium mining and broad knowledge of world-wide trends and experiences of other U.S. states and foreign nations with uranium mining. Unfortunately, the provisional committee does not include experts with such level of expertise. We, therefore, respectfully request that BESR expand the committee to include at least four experts who have studied the effects of uranium mining world-wide.
It is also unclear from the published bios of the provisional committee members whether anyone of them has an expertise required for evaluating post-mining impacts of tailings impoundments. We, therefore, respectfully request that BESR ensure that an expert in this very specific area is included in the committee.
Thank you very much for your time and attention. We hope that BESR will give sufficient consideration to the concerns raised in these comments and will ensure that this very important study proceeds in a most transparent manner.
Sincerely,
S.J. Dunavant, Jr.
Chairman
Southside Concerned Citizens, Inc.
Halifax, VA
Rev. Walter Stark
Cumberland Countians for Peace & Justice
Pleasant Hill, TN
Donald B. Clark
Network for Environmental & Economic Responsibility
United Church of Christ
Pleasant Hill, TN
Patricia T. Birnie,
GE Stockholders' Alliance
Tucson, AZ
Joanne Sheehan
New England War Resisters League,
Norwich, CT
Scott Sklar
The Stella Group, Ltd.
Arlington, VA
Paula Gotsch
GRAMMES
Normandy, NJ
Judy Treichel
Nevada Nuclear Waste Task Force
Las Vegas, NV
Deb Katz
Vermont Citizens Action
Hancock Vermont
Marilyn McCulloch
The Carrie Dickerson Foundation
Tulsa, OK
Rinaldo Brutoco
World Business Academy
Santa Barbara, CA
Madeleine Austin
World Business Academy
Honolulu, HI
Joni Arends
Concerned Citizens for Nuclear Safety
Santa Fe, NM
Marylia Kelley
Tri-Valley CAREs
CA, USA
Alice Slater
Nuclear Age Peace Foundation
New York, NY
Nina Bell, J.D.
Northwest Environmental Advocate
Portland OR
Lloyd K. Marbet
Oregon Conservancy Foundation
Boring, Oregon
Mary Davis
Ecoperspectives
Lexington, KY
Nikos Pastos
Center for Water Advocacy
Moab, UT
HOMER, AK
Portland, OR
Tom Ferguson Foundation for Global Community
Atlanta, GA
Bob Darby
Food Not Bombs
Atlanta, GA
Robert M. Gould, MD
SanFrancisco/Bay Area Chapter: Physicians for Social Responsibility
San Francisco, CA
Cara Campbell
Ecology Party
Ft. Lauderdale, FL
Mark Haim
Missourians for Safe Energy
Columbia, MO
Ken Bossong
SUN DAY Campaign
Takoma Park, MD
Bonnie Urfer
Nukewatch
Luck, WI
John LaForge
Nukewatch
Luck, WI
Michael Casper
Larson Transportation Institute
University Park, PA
Christopher LaForge
Great Northern Solar
Port Wing, WI
William S. Linnell
Cheaper, Safer Power
Portland, ME
Anna Aurilio
Environment Virginia
Richmond, VA
Dagmar Fabian
Crabshell Alliance
Cockeysville, MD
Hope Taylor,MSPH
Clean Water for NC
Asheville & Durham, NC
Lynn Sims
Don't Waste Oregon
Portland, OR
Greg Wingard
Director Waste Action
Seattle, WA
Ellen Thomas
Proposition One Campaign
Washington, DC
Egan O'Connor
Committee for Nuclear Responsibility
San Francisco CA
Mary Beth Brangan
The Ecological Options Network, EON
Bolinas, CA
Elena Day
People's Alliance for Clean Energy
Charlottesville, VA
Patricia Gillis
Voices for Earth Justice
Southfield, MI
Douglas Meiklejohn
New Mexico Environmental Law Center
Santa Fe, NM
Ernest Fuller
CCSS (Concerned Citizens for SNEC Safety)
Six Mile Run, PA
Carolyn Treadway
No New Nukes
Normal, IL
Donna
Alliance For A Clean Enviornment
Pottstown, PA
Linda Seeley
Terra Foundation
San Luis Obispo, CA
Dr. F. Taylor
Hilton Head for Peace
Hilton Head, SC
Jeff Unsicker
Nuclear Free Vermont
Brattleboro, VT
Cynthia Weehler
Energia Mia
San Antonio, Texas
BRIGITTE FORTIN
Catoctin Group, Maryland Sierra Club
Myersville, MD
Suzanne Miller
AFSC (American Friends Service Committee
Cleveland Heights, OH
Wells Eddleman
Staff Scientist
NC Citizens Research Group, Durham NC
Glenn Carroll
Nuclear Watch South
Atlanta, GA
Andrew Fellows
Chesapeake Regional Director
Clean Water Action
Washington, DC
Janet Greenwald
Co-coordinator Citizens for Alternatives to Radioactive Dumping
Albequrque, NM
Molly Johnson Grandmothers for Peace/San Luis Obispo County Chapter
San Miguel, CA
Ralph Hutchison
Coordinator
Oak Ridge Environmental Peace Alliance
Oak Ridge, TN
Alice Slater
Nuclear Age Peace Foundation, NY
New York , NY
Judy Treichel
Executive Director
Nevada Nuclear Waste Task Force
Byron & Janice Motley
Chatham, VA
Barbara M. Hancock
Pittsville, VA
Terry H. Andrews
Halifax, VA
Nancy Gillespie
Roanoke, VA
Tony Dix
Blair, VA
Albert Nunez
Takoma Park, MD
Hattie Nestel
Brattelboro, VT
Hunter Austin
Hurt, Virginia
Lynnea Smith
Crownpoint, NM
Bert Marian
Addison, ME
Karl J. Novak
Hinesburg, Vt
Rebecca L. Ramsay
Cambridge, MA
Barbara Antonoplos
Atlanta, GA
David N. Pyles
Nelson, NH
Denise Jakobsberg
Mt. Rainier, MD
Jessie Dodson
Richmond, VA
Ann Van Kuren
State College, PA
Jonathan M. Block,
Santa Fe, NM
Deborah Dix
Blairs, VA
Bob Brister
Salt Lake City, UT
Natalie Hanson
Lansing, MI
Gail Merrill
New Canaan, CT
Lisa Kasenow
Sanibel, Florida
Tom and Nancy Florsheim
Santa Fe, NM
Diane Pontius
Evanston, IL
Roy C. Treadway
Normal, IL
Leah R. Karpen
Asheville, Nc
Elizabeth Covington
Richmond, Va
Peggy Pryor
Andrews County, TX
Melodye Pryor
Andrews County, TX
Holly Rose
New Smyrna Beach, FL
June Sevilla
Lusby, MD
James Wishart
Lexington Park, MD
Maya Be
Seattle, WA
Dudley Lindsley
Leonardtown, MD
Dr. Thomas B. Cochran
Arlington, VA
Lee Ann Olohan
Owings, MD
Charles K. Johnson
Portland, OR
Gary Shaw
Croton on Hudson, NY
Olga Kolotushkina
Annandale, VA
Karen B. Maute
Danville, VA
Valentin Lukashuk
Fairfax, VA
Joan R. Sprinkle (Mrs. James D.)
Danville, VA
Ricky Simpson
Altavista, VA
Andrey and Larisa Lukashuk
Mount Solon, VA
Deborah Quinn Lovelace
Gretna, VA
Carolyn A. Gibson
Ringgold, VA
Andrew Lester
Keeling, VA
Winnie Pruitt
Danville, VA
Wm. and Barbara Winn
Martinsville, VA
Peyton Wrenn
Blairs, VA
Sergey and Dina Lukashuk
Harrisonburg, VA
Linda Worsley
Chatham, VA
Robert Pruitt
Danville, VA
Barbara Bass Thompson
Chatham, Virginia
Frank H. (Jesse) Andrews, Jr.
Halifax, VA
Kenneth D. And Karen H. Schneider
Caswell County, NC
Phillip Lovelace
Gretna, VA
Ann M. Rogers
Boones Mill, VA
Annette G. Ayres
Summerfield, NC
Barbara Hudson
Chatham, VA
Janice H. Overbey
Chatham, VA
Cory Greer
Roanoke, VA
George Warren Stanhope
Chatham, VA
Janet Lincoln Stanhope
Chatham, VA
Richard Austin
Hurt, VA
Laura D. Meder
Danville, VA
Virginia Anne Cockrell
Danville, VA
Cara Cooper and Jessica Okaty
Students for Environmental Action at FIU and FL Youth Environmental and Sustainability Coalition
Miami FL
Dr. David Feary
Study Director
Board on Earth Sciences and Resources
Division on Earth and Life Studies
National Academy of Sciences
500 Fifth Street, NWWashington, DC 20001
Re: The Composition of Provisional Committee for the Study of
Uranium Mining in Virginia, DELS-BESR-09-06
Dear Dr. Feary:
We appreciate the opportunity to comment on the composition of the provisional study committee on uranium mining in Virginia, established to examine the scientific, technical, environmental, human health, safety, and regulatory aspects of uranium mining, milling, and processing as they relate to the Commonwealth of Virginia. The committee’s work is extraordinarily important, as the findings of the study will assist the Commonwealth in determining whether uranium mining, milling, and processing can be undertaken in a manner that safeguards the environment, natural and historic resources, agricultural lands, and the health and well-being of its citizens.
Proposed uranium mining has been a controversial issue in the Commonwealth of Virginia since late 1970s when the uranium mining deposits were first discovered. For years, this matter has been an issue of utmost concern for the communities that may potentially be affected by uranium mining. For these reasons, it is very important that this uranium mining study be performed by a well-balanced and objective panel of scientists and experts who are free of any obligations to entities that may either benefit or be disadvantaged by the findings of this study.
Unfortunately, it appears that several members of the provisional committee have conflicts of interest that could significantly impair their objectivity and further damage the credibility of this study in the eyes of the public. As more fully discussed below, we respectfully request that the Board on Earth Sciences and Resources (thereafter, BESR) conduct a review of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, and Dr. Michel Cuney for a potential conflict of interest, and remove Mr. Henry Schnell from the study committee due to an apparent conflict of interest.
It has been widely reported in the Virginia local press that the funding for this study is coming from Virginia Uranium, Inc., the company seeking to lift Virginia’s 1982 ban on uranium mining, and that the Virginia Center for Coal and Energy Research at the Virginia Polytechnic Institute and State University is serving as a mere conduit for funneling the study funds to the National Research Council. The Governing Board Executive Council of National Academies was apprised of this situation in an October 2, 2009 letter signed by over 30 concerned citizens. Because of the nature of the end source of funding, the study’s credibility is already being questioned by the public.
Under these circumstances, it is especially important that the study process be conducted in a manner ensuring transparency and an ample opportunity for public comment. Accordingly, we respectfully request that the BESR extend the comment period until August 30, 2010. Pursuant to Section 15(b) of the Federal Advisory Committee Act (thereafter, FACA), the National Academy of Sciences “shall … provide a reasonable opportunity for the public to comment on … appointments before they are made or… in the period immediately following the appointments.” While a 20-day comment period has been the National Academies’ long-standing practice, limiting it to 20 days is not required by law. In this particular case, given the controversial nature of the issue to be examined in the uranium mining study, and the fact that most of Virginia residents received either no notice or insufficient notice of the commencement of the comment period, the BESR should extend the public comment period until August 30, 2010 to allow all interested parties to comment on the composition of the provisional committee.
In addition, we urge the BESR to conduct public hearings to provide an open public forum for interested parties to participate in the study committee discussions in accordance with Section 15(b)(3) of FACA, and to promptly make available to the public a summary of any committee meetings and any materials provided to the study committee in compliance with Sections 15(b)(3)-(4). The general public should also be provided with a sufficient notice of at least thirty (30) days prior to the date of the public meeting and an opportunity to submit written comments on the public committee discussions.
We believe that public meetings should be conducted so as to include all the locations in the Commonwealth of Virginia that may potentially be affected by uranium mining. Historically, uranium companies have shown interest in uranium in Culpeper, Fauquier, Franklin, Floyd, Henry, Madison, Nelson, Orange, Patrick, and Pittsylvania Counties and leased mineral rights on approximately 50,000 acres in the 1980s. Downstream from these areas, there are counties and municipalities whose drinking water could be affected by uranium mill tailings. These include Brunswick, Fairfax, Halifax, Mecklenburg, Virginia Beach, Chesapeake, and others. If the uranium mining ban is lifted, we would likely see exploration for uranium in the black shale of Southwest Virginia, in crystalline granite throughout the Blue Ridge, and in sedimentary rock in the Coastal Plains, as well as further exploration in the Northern and Southern Piedmont. Conducting public meetings at multiple locations will ensure the utmost degree of transparency of the study process for such a controversial issue as uranium mining.
Potential Conflict of Interest
The National Academies have established policies and procedures for addressing potential conflicts of interest to be used by committees in the development of its reports. This policy states that “[i]t is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest. For this purpose, the term "conflict of interest" means any financial or other interest which conflicts with the service of the individual because it (1) could significantly impair the individual's objectivity or (2) could create an unfair competitive advantage for any person or organization. Except for those situations in which the institution determines that a conflict of interest is unavoidable and promptly and publicly discloses the conflict of interest, no individual can be appointed to serve (or continue to serve) on a committee of the institution used in the development of reports if the individual has a conflict of interest that is relevant to the functions to be performed.”
We wish to bring the following matters of concern to the attention of the National Academies and the BESR regarding employment, existing fiduciary duties, consulting services, and promotional activities of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, Dr. Michel Cuney, and Mr. Henry Schnell that to the best of our knowledge have not been publicly disclosed as potential conflicts of interest in regard to the uranium mining study.
Dr. Corby G. Anderson currently serves as s trustee for the Northwest Mining Association, a trade association, whose stated purpose is to represent and inform members on legislative, regulatory and technical issues, to support and advance the mineral resource and related industries, and to foster and promote economic opportunity. Among the members of the Northwest Mining Association are Denison Mines Corp., a publicly traded company operating three uranium mines and two uranium mills in North America, and Uranium One Inc., one of the world’s largest publicly traded uranium producers. As a trustee of this trade association, Dr. Anderson has a fiduciary duty to the association and its members to act in their best interests. Although the study is designed to examine the feasibility of uranium mining in the Commonwealth of Virginia, the outcome of this study, similar to all studies completed by the National Academies, will set precedent for the entire uranium mining industry here in the United States and possibly around the world. The study findings will serve as the basis for the Virginia General Assembly’s determination of whether to lift the 28-year ban on uranium mining. The Virginia General Assembly’s action on the uranium mining ban has a potential of impacting economic opportunities for many uranium mining companies, including the companies that are corporate members of the Northwest Mining Association.
In addition, to the best of our knowledge, Dr. Anderson routinely undertakes contracted projects for global industrial client projects, including serving as an expert witness in mining litigation. Under the National Academies’ Policy on Committee Composition and Balance and Conflicts of Interest, a consulting relationship, such as serving as an expert witness in litigation, constitutes a potential financial conflict of interest.
Furthermore, Anderson also serves on the Board of Directors of Phoenix Minerals, Inc. and is President and COO of Getty Copper Inc. Both are publicly traded mining companies. In connection with this, we respectfully request that BESR investigate whether any of the two companies currently operate a uranium mine or mill and whether they presently have plans to mine or mill uranium.
Dr. Lawrence W. Barnthouse is an owner of LWB Environmental Services, Inc., a consulting company that provides ecological risk assessments and risk-based environmental restoration planning. Among Dr. Barnthouse’s clients are large law firms that represent clients from all over the country in environmental litigation and environmental regulatory proceedings. This appears to indicate that Dr. Barthhouse serves as an expert witness for those law firms and their clients on the issues that may be the subject matter of the uranium mining study. The National Academies’ policy on conflicts of interest provides that serving as an expert witness is a type of consulting relationship that may constitute a financial interest. Accordingly, we request that BESR further investigate Dr. Barnthouse for a conflict of interest based on the nature of the consulting services he provides to his clients. BESR’s review should address whether Dr. Barnthouse serves as an expert witness on issues that will be examined in the uranium mining study and whether he provides expert testimony on behalf of uranium mining companies, regardless of whether they are his direct clients or clients of his clients.
Dr. Michael Cuney’s industry consultation includes work for major uranium mining companies, such as Areva and Uranor Inc. The findings of the uranium mining study will determine future economic opportunities for Dr. Cuney’s corporate clients in the Commonwealth of Virginia. Thus, Dr. Cuney’s consulting relationship with uranium mining companies constitutes a potential conflict of interest and warrants review by BESR.
In addition, as stated in Dr. Cuney’s biography, he has visited and/or worked on most major uranium deposits of the world. BESR should investigate in what capacity Dr. Cuney traveled to all those mining sites, who funded his trips and whose interests he represented during those trips and to which companies he provided the services in connection with the trips, and whether these companies continue to use his services.
Furthermore, Dr. Cuney participates in numerous international conferences. In fact, he was a speaker at the Global Uranium International Conference held in Colorado in May 2009, where the Coles Hill, VA deposit was discussed at length. We, therefore, request that BESR require Dr. Cuney to disclose whether he received any honorarium or travel expense reimbursements for his participation in these activities and any other uranium mining conferences and who sponsored his trips to such conferences.
Mr. Henry Schnell has an apparent conflict of interest based on his employment. Mr. Schnell holds a senior position in the Mining Business Unit with Areva NC Inc., a multinational company that owns and operates, either directly or through its subsidiaries, uranium mines in many parts of the world, including North America. Specifically, Areva’s subsidiary Pathfinder Mines Corporation operates large uranium mines in Wyoming that are currently undergoing reclamation. As stated above, the study’s finding will set precedent for the entire uranium mining industry and will have a potential to affect economic opportunities for many uranium mining companies, including Mr. Schnell’s employer, Areva.
In addition, we would like to bring to BESR’s attention the fact that Areva Inc. is actively involved in promoting uranium mining in Virginia. Virginia Energy Independence Alliance (thereafter, VEIA), whose two out of three corporate members are Areva Inc. and Virginia Uranium, Inc., has been very outspoken and pro-active in its campaign to support uranium mining in the Commonwealth. The VEIA Chairman Ray Ganthner has just retired from his position of Senior Vice President with Areva. Most recently Mr. Ganthner appeared on behalf of VEIA at the June 22, 2010 public hearing conducted by the Virginia Coal and Energy Commission on uranium mining and spoke publicly on behalf of VEIA in favor of uranium mining. Because VEIA at this time has only three corporate members, one of which is Areva Inc., it is reasonable to conclude that when the VEIA Chairman speaks on the subject of uranium mining, it represents Areva’s views and promotes Areva’s best interests.
This demonstrates that Mr. Schnell’s employer Areva may directly benefit or may be disadvantaged by the findings of the uranium mining study. Because of his employment and his employer’s particular interest in uranium mining in Virginia, Mr. Schnell’s objectivity may be significantly comprised. Mr. Schnell’s participation in this study may create an unfair competitive advantage for Areva. Accordingly, we request that Mr. Schnell be removed from the study committee due to his apparent conflict of interest.
Balance of the Study Committee
Under the Statement of Task for the uranium mining study, the study committee is called upon to examine 12 questions covering a wide range of areas from legal framework to public health and safety to mining methods to reclamation and waste management to cultural issues to geology, climate and water management, etc. Despite the fact that the scope of the uranium mining study is vast and complex, the study committee is comprised of only 13 experts. It appears that some of the issues included in the study will be examined by only one expert. A committee that has only one expert per issue cannot be characterized as balanced because the study process will fail to ensure peer review on one or more issues. For this reason, we believe that the committee membership must be expanded to include more experts, especially in the areas highlighted below.
The first item of the Statement of Task directs the study committee to “assess the potential short- and long-term occupational and public health … considerations … including the potential human health risks.” Item 4 directs to “analyze the impact of uranium mining, milling, processing, and reclamation operations on public health.” Comprehensive examination of items 1 and 4 of the Statement of Task requires an expert in occupational and public health, as well as a medical doctor. The provisional committee currently includes public and occupational health experts and epidemiologists but no medical doctor. We, therefore, request that the BESR appoint an expert with the medical doctor degree to the study committee.
Pursuant to item 4 of the Statement of Task, the study committee is to “analyze the impact of uranium mining, milling, processing, and reclamation operations … at sites with comparable .. hydrologic … characteristics to those found in the Commonwealth.” In addition, item 9 directs the study committee to “identify the issues that may need to be considered regarding the quality and quantity of groundwater and surface water… As relevant, water and waste management … may also be considered.” The potential impact of uranium mining on water supply has been of utmost concern for the communities where uranium mines may be developed and to the communities, like Fairfax and Halifax Counties and the City of Virginia Beach, and all the communities in the Roanoke River Basin including those in North Carolina whose sources of drinking water are located in areas where uranium mining is likely to occur should the uranium mining ban is lifted. For this reason, we respectfully request BESR to ensure that the study committee includes a sufficient number of experts with the expertise in hydrology and water-related issues.
Item 5 of the Statement of Task directs the study committee to “review the … cultural settings … in the Commonwealth of Virginia.” A comprehensive analysis of the cultural settings requires an expertise in environmental justice. Unfortunately, it is not apparent from the information posted on the credentials of the provisional committee members whether the committee includes experts in environmental justice. Because uranium mining is likely to affect many communities with relatively low socioeconomic status and very little influence over legislative decisions and limited access to the legal system, it is very important that the issue of environmental justice be examined thoroughly in the study. To this end, the study committee should be expanded to include at least two experts in environmental justice with experience of addressing these issues in the communities affected by uranium mining. We would welcome an opportunity to provide nominations for all above-mentioned areas of expertise.
In addition, it appears that the majority of questions under the Statement of Task require global expertise in uranium mining and broad knowledge of world-wide trends and experiences of other U.S. states and foreign nations with uranium mining. Unfortunately, the provisional committee does not include experts with such level of expertise. We, therefore, respectfully request that BESR expand the committee to include at least four experts who have studied the effects of uranium mining world-wide.
It is also unclear from the published bios of the provisional committee members whether anyone of them has an expertise required for evaluating post-mining impacts of tailings impoundments. We, therefore, respectfully request that BESR ensure that an expert in this very specific area is included in the committee.
Thank you very much for your time and attention. We hope that BESR will give sufficient consideration to the concerns raised in these comments and will ensure that this very important study proceeds in a most transparent manner.
Sincerely,
S.J. Dunavant, Jr.
Chairman
Southside Concerned Citizens, Inc.
Halifax, VA
Rev. Walter Stark
Cumberland Countians for Peace & Justice
Pleasant Hill, TN
Donald B. Clark
Network for Environmental & Economic Responsibility
United Church of Christ
Pleasant Hill, TN
Patricia T. Birnie,
GE Stockholders' Alliance
Tucson, AZ
Joanne Sheehan
New England War Resisters League,
Norwich, CT
Scott Sklar
The Stella Group, Ltd.
Arlington, VA
Paula Gotsch
GRAMMES
Normandy, NJ
Judy Treichel
Nevada Nuclear Waste Task Force
Las Vegas, NV
Deb Katz
Vermont Citizens Action
Hancock Vermont
Marilyn McCulloch
The Carrie Dickerson Foundation
Tulsa, OK
Rinaldo Brutoco
World Business Academy
Santa Barbara, CA
Madeleine Austin
World Business Academy
Honolulu, HI
Joni Arends
Concerned Citizens for Nuclear Safety
Santa Fe, NM
Marylia Kelley
Tri-Valley CAREs
CA, USA
Alice Slater
Nuclear Age Peace Foundation
New York, NY
Nina Bell, J.D.
Northwest Environmental Advocate
Portland OR
Lloyd K. Marbet
Oregon Conservancy Foundation
Boring, Oregon
Mary Davis
Ecoperspectives
Lexington, KY
Nikos Pastos
Center for Water Advocacy
Moab, UT
HOMER, AK
Portland, OR
Tom Ferguson Foundation for Global Community
Atlanta, GA
Bob Darby
Food Not Bombs
Atlanta, GA
Robert M. Gould, MD
SanFrancisco/Bay Area Chapter: Physicians for Social Responsibility
San Francisco, CA
Cara Campbell
Ecology Party
Ft. Lauderdale, FL
Mark Haim
Missourians for Safe Energy
Columbia, MO
Ken Bossong
SUN DAY Campaign
Takoma Park, MD
Bonnie Urfer
Nukewatch
Luck, WI
John LaForge
Nukewatch
Luck, WI
Michael Casper
Larson Transportation Institute
University Park, PA
Christopher LaForge
Great Northern Solar
Port Wing, WI
William S. Linnell
Cheaper, Safer Power
Portland, ME
Anna Aurilio
Environment Virginia
Richmond, VA
Dagmar Fabian
Crabshell Alliance
Cockeysville, MD
Hope Taylor,MSPH
Clean Water for NC
Asheville & Durham, NC
Lynn Sims
Don't Waste Oregon
Portland, OR
Greg Wingard
Director Waste Action
Seattle, WA
Ellen Thomas
Proposition One Campaign
Washington, DC
Egan O'Connor
Committee for Nuclear Responsibility
San Francisco CA
Mary Beth Brangan
The Ecological Options Network, EON
Bolinas, CA
Elena Day
People's Alliance for Clean Energy
Charlottesville, VA
Patricia Gillis
Voices for Earth Justice
Southfield, MI
Douglas Meiklejohn
New Mexico Environmental Law Center
Santa Fe, NM
Ernest Fuller
CCSS (Concerned Citizens for SNEC Safety)
Six Mile Run, PA
Carolyn Treadway
No New Nukes
Normal, IL
Donna
Alliance For A Clean Enviornment
Pottstown, PA
Linda Seeley
Terra Foundation
San Luis Obispo, CA
Dr. F. Taylor
Hilton Head for Peace
Hilton Head, SC
Jeff Unsicker
Nuclear Free Vermont
Brattleboro, VT
Cynthia Weehler
Energia Mia
San Antonio, Texas
BRIGITTE FORTIN
Catoctin Group, Maryland Sierra Club
Myersville, MD
Suzanne Miller
AFSC (American Friends Service Committee
Cleveland Heights, OH
Wells Eddleman
Staff Scientist
NC Citizens Research Group, Durham NC
Glenn Carroll
Nuclear Watch South
Atlanta, GA
Andrew Fellows
Chesapeake Regional Director
Clean Water Action
Washington, DC
Janet Greenwald
Co-coordinator Citizens for Alternatives to Radioactive Dumping
Albequrque, NM
Molly Johnson Grandmothers for Peace/San Luis Obispo County Chapter
San Miguel, CA
Ralph Hutchison
Coordinator
Oak Ridge Environmental Peace Alliance
Oak Ridge, TN
Alice Slater
Nuclear Age Peace Foundation, NY
New York , NY
Judy Treichel
Executive Director
Nevada Nuclear Waste Task Force
Byron & Janice Motley
Chatham, VA
Barbara M. Hancock
Pittsville, VA
Terry H. Andrews
Halifax, VA
Nancy Gillespie
Roanoke, VA
Tony Dix
Blair, VA
Albert Nunez
Takoma Park, MD
Hattie Nestel
Brattelboro, VT
Hunter Austin
Hurt, Virginia
Lynnea Smith
Crownpoint, NM
Bert Marian
Addison, ME
Karl J. Novak
Hinesburg, Vt
Rebecca L. Ramsay
Cambridge, MA
Barbara Antonoplos
Atlanta, GA
David N. Pyles
Nelson, NH
Denise Jakobsberg
Mt. Rainier, MD
Jessie Dodson
Richmond, VA
Ann Van Kuren
State College, PA
Jonathan M. Block,
Santa Fe, NM
Deborah Dix
Blairs, VA
Bob Brister
Salt Lake City, UT
Natalie Hanson
Lansing, MI
Gail Merrill
New Canaan, CT
Lisa Kasenow
Sanibel, Florida
Tom and Nancy Florsheim
Santa Fe, NM
Diane Pontius
Evanston, IL
Roy C. Treadway
Normal, IL
Leah R. Karpen
Asheville, Nc
Elizabeth Covington
Richmond, Va
Peggy Pryor
Andrews County, TX
Melodye Pryor
Andrews County, TX
Holly Rose
New Smyrna Beach, FL
June Sevilla
Lusby, MD
James Wishart
Lexington Park, MD
Maya Be
Seattle, WA
Dudley Lindsley
Leonardtown, MD
Dr. Thomas B. Cochran
Arlington, VA
Lee Ann Olohan
Owings, MD
Charles K. Johnson
Portland, OR
Gary Shaw
Croton on Hudson, NY
Olga Kolotushkina
Annandale, VA
Karen B. Maute
Danville, VA
Valentin Lukashuk
Fairfax, VA
Joan R. Sprinkle (Mrs. James D.)
Danville, VA
Ricky Simpson
Altavista, VA
Andrey and Larisa Lukashuk
Mount Solon, VA
Deborah Quinn Lovelace
Gretna, VA
Carolyn A. Gibson
Ringgold, VA
Andrew Lester
Keeling, VA
Winnie Pruitt
Danville, VA
Wm. and Barbara Winn
Martinsville, VA
Peyton Wrenn
Blairs, VA
Sergey and Dina Lukashuk
Harrisonburg, VA
Linda Worsley
Chatham, VA
Robert Pruitt
Danville, VA
Barbara Bass Thompson
Chatham, Virginia
Frank H. (Jesse) Andrews, Jr.
Halifax, VA
Kenneth D. And Karen H. Schneider
Caswell County, NC
Phillip Lovelace
Gretna, VA
Ann M. Rogers
Boones Mill, VA
Annette G. Ayres
Summerfield, NC
Barbara Hudson
Chatham, VA
Janice H. Overbey
Chatham, VA
Cory Greer
Roanoke, VA
George Warren Stanhope
Chatham, VA
Janet Lincoln Stanhope
Chatham, VA
Richard Austin
Hurt, VA
Laura D. Meder
Danville, VA
Virginia Anne Cockrell
Danville, VA
Cara Cooper and Jessica Okaty
Students for Environmental Action at FIU and FL Youth Environmental and Sustainability Coalition
Miami FL
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