White Paper


Forgotten People

P.O. Box 1661

Tuba City, AZ  86045

http://www.forgottennavajopeople.org

E-mail: info@forgottenpeople.org

(928) 401-1777

White Paper

Uranium Transport Ban Amendment to the Diné Resources Protection Act of 2005 amending Title 18 of the Navajo Nation Code

A legacy of uranium mining has contaminated Navajo land and water resources.  Close to a hundred percent of the demand for uranium stemmed out of the U.S. government’s pursuit for nuclear weaponry during the Cold War. [1] From 1944 to 1986 across the Navajo Nation, mine operators extracted nearly 4 million tons of uranium ore which brought the ore to the surface.

The Navajo Nation reports the presence of over 1300 abandoned unreclaimed mines and the leeching of uranium from the slag piles into drinking water supplies was damaging water supplies. [2]  Up to 25% of the unregulated sources in the western Navajo reservation exceed drinking water standard for kidney toxicants including uranium. [3]  The Navajo miners were regularly exposed to radioactive conditions that were sometimes in excess of 750 times the generally accepted radon limits, which led to many instances of cancer, death, and other diseases. [4]  “Concentrated uranium was being blown all over the land surrounding the mills” for up to “a radius of a half a mile or so” which led to further contamination. Even after uranium mining ceased there were still radioactive problems that persisted through the mill tailings (the leftovers from the conversion process). [5]

The Ford Foundation’s report of Nuclear Energy Policy found that when pure uranium is removed from the ore, 85% of the radioactivity is left in the tailings during the mining process. Uranium ore tailings emit 500 times the natural level of radon gas. The most prevalent isotope in uranium ore is Uranium-238 consisting of a half life of 4.5bn years. [6] Life of the containment cells – plastic and concrete – have a life span of 200-500 years.  When mines are abandoned, slag piles that are left on the surface face weatherization such as wind and rain that break apart the rocks. The remaining low-grade uranium ore and other chemicals become exposed to weatherization. Rain water seeps through the pilings and disturbed earth leeching toxic and radioactive chemicals (known as Acid Rock Drainage (ARD) – or in the case of uranium, thorium and radium, Radioactive Rock Drainage (RRD)) into the water supplies. [7]

Uranium in the drinking water causes multiple health impacts, including lung cancer from inhalation of radioactive particles, as well as bone cancer and impaired kidney function from exposure to radionuclides in drinking water. [8]  Kidney disease form uranium contamination is triple on the Navajo Reservation than that of the National average. [9]

Before the cause was known, doctors working on the Navajo Reservation thought they had discovered a genetic disease that caused “Navajo Neuropathy”, which was associated with muscular degeneration, ulcers, vision weakness, and other severe health issues. [10] Navajo Neuropathy and other severe health issues are associated with drinking uranium contaminated water.  In spite of high rates of cancer, diabetes, autoimmune disease, kidney failure and birth defects, there has been no comprehensive study of public health in uranium and coalmine communities.  People who were believed to have a “special immunity” to cancer saw death rates double from the early 1970s to the late 1990s.  During this same time, the overall cancer rate in the general population of the United States declined. [11]

Gastric cancer rates up 50% during the 1990s among Navajo people in two New Mexico counties with uranium sites. Uranium has been linked to reproductive cancers, and a sharp increase in breast, ovarian, and other cancers among teenage girls.  Today, cancer rates and reproduction-organ cancers in teenage Navajo girls living near mine tailings are 17 times higher than the average of girls in the United States.  [12]

In 2005, Navajo Nation President Joseph Shirley Jr. signed the Diné Natural Resources Protection Act outlawing uranium mining and processing on the Navajo reservation stating: “No person shall engage in uranium mining and processing on any sites within Navajo Indian Country.”

On July 21, 2009, Secretary of Interior Ken Salazar ordered a 2-year withdrawal of over 1 million acres of Bureau of Land Management (BLM) and National Forest lands near the Grand Canyon from new hard-rock mining claims, including uranium mining claims. This will provide time for studies and analyses of a more lengthy withdrawal.

The US government Department of the Interior recognizes National Environmental Policy Act (NEPA) Responsibilities under Executive Order 12898 which mandates all actions specifically analyze and evaluate the impacts of any proposed projects such as the transport of uranium across Navajo lands on minority and low-income populations and communities, as well as the equity of the distribution of the benefits and risks of those decisions.

On June 15, 2010, the full 10th U.S. Circuit Court of Appeals in Denver ruled in a 6-5 decision that the U.S. Environmental Protection Agency erred when it determined that a parcel of land near the Navajo community of Church Rock was Indian land. The decision means that Hydro Resources Inc. can seek an underground injection control permit from the state of New Mexico rather than the EPA, which has permitting authority on tribal lands. [13]

Three of the dissenting justices in the 10th U.S. Circuit Court decision ruling against the US EPA and Navajo concerns about renewed uranium mining by Hydro Resources Inc. (HRI) noted “the externalities produced by a mining operation – including pollution, traffic, and the aesthetic harms by having a large mining operation nearby – also affect the surrounding community.” They cited “the largest nuclear spill in U.S. history” near Church Rock in 1979 that caused extensive damage and contamination. [14]


All transportation is associated with some potential health risk; namely, adverse health effects from inhalation of vehicle exhausts, and risk of injury or death associated with physical trauma from vehicle accidents. Statistically, these risks depend on the distance traveled and not on the type of cargo being transported.   However, the risks are greatly increased when the half-life of radon daughters lasts 5.3 billion years endangering Navajo lands, water sources and public health. [15] 

Forgotten People believes that an analysis of disproportionately high and adverse impacts needs to accurately identify and disclose all significant environmental impacts associated with a proposed action such as the transport of uranium across Navajo lands to protect the public health and safety and enlarge the nature of stewardship undertaken by the Navajo Nation.

Forgotten People proposes the Navajo Nation amend the Diné Resources Protection Act of 2005 to include a uranium transport ban across Navajo lands.

Text of the Bill

In order to preserve public health and safety, No uranium can be transported across Navajo lands except for the purpose of remediation.

Detail of the Bill

The Navajo Nation hereby enacts a uranium transport ban across Navajo lands that will be applied to the Diné Resources Protection Act of 2005 amending Title 18 of the Navajo Nation Code.  The uranium transport ban cannot be lifted without the repeal of the Act and simply entrenches a ban across Navajo lands to protect the public health and safety of the Diné people and enlarge the nature of stewardship undertaken by the Navajo Nation to protect Navajo land and water resources.

Purpose of the Bill

The purpose of the Bill is to implement a commitment given in the Diné Resources Protection Act of 2005 amending Title 18 of the Navajo Nation Code to include a uranium transport ban across Navajo lands to protect the public health and safety of the Diné people and enlarge the nature of stewardship undertaken by the Navajo Nation to protect Navajo land and water resources.

Effect of the Bill

The effect of the Bill will be to entrench the ban on uranium transport that will be applied to the Diné Resources Protection Act of 2005 amending Title 18 of the Navajo Nation Code(Attachment 1). Once the Bill is passed and enacted, the uranium transport ban across Navajo lands could not be lifted without the repeal of the Act.  This Bill simply entrenches a ban already applied to uranium mining. 

GUIDANCE

Lack of safety and adequate training:

  1. Lack of safety and adequate training perpetuates a legacy of uranium mining contamination. Leana Hosea, Journalist, British Broadcasting Corporation World News Service (BBC) prepared the following links of footage of Denison AZ-1 mine, Denison mines interview and an interview with uranium miners at the Arizona 1 mine and reporter piece to camera:
  1. http://www.youtube.com/watch?v=Ro4pvTtvwxE
  2. http://www.youtube.com/watch?v=2TXjA8kqWoI
  3. http://www.youtube.com/watch?v=ZK41QrVFUoc&feature=related
  4. http://www.youtube.com/watch?v=LewBwozOQPU&feature=related

      miners

  1. http://www.youtube.com/watch?v=xo0vsoO6fSo&feature=related [16]

Truck Accidents

  1. Moab Cleanup project Truck Accident. A truck carrying uranium mill tailings from a Moab cleanup project headed by EnergySolutions tipped over and spilled some of the radioactive dirt last Wednesday (Oct. 14, 2009). The multimillion-dollar cleanup project was suspended until Tuesday (Oct. 20, 2009) for a safety evaluation, EnergySolutions spokesman Mark Walker said. EnergySolutions had been carting dirt up a haul road at the site Wednesday evening when the driver came too close to the shoulder and the truck tipped over, Walker said. The driver was fine but taken to the hospital for a precautionary evaluation, he said.   (Deseret News Oct. 18, 2009) [17]
  2. Empty transportation containers exceeding contamination limits at White Mesa Uranium Mill. NRC Preliminary Notification PNO-IV-00-008 (March 2, 2000) High Chloroform levels found in groundwater.  High chloroform at levels 47 times higher than allowed by Utah state rules was found in a groundwater monitoring well at the White Mesa uranium mill. The discovery prompted the Utah Department of Environmental Quality to issue a “notice of violation” of the state’s groundwater-protection rules. Denver-based International Uranium Corp. was given 30 days to develop a plan to determine the source of the contamination. (Salt Lake Tribune, Deseret News, Aug 31, 1999) [18]
  1. This happened in spite of Dennison Mine’s Transportation Policy for Shipments of Colorado Plateau Uranium Ores to the White Mesa Uranium Mill identifying shipping responsibilities and practices to be employed when shipping uranium ore from a Colorado Plateau mine (the “Mine”) by truck to the White Mesa Uranium Mill (the “Mill”) to maintain compliance with applicable requirements of the U.S. Department of Transportation (“DOT”) regulations at Title 49 of the Code of Federal Regulations. [19]
  2. UF6 truck overturns and catches fire in Summers County, West Virginia. At midnight, a tractor trailer truck overturned and caught fire on I-64 near Exit 139 at Sandstone, WV, which is in Summers County. A container containing Uranium Hexafloride was on the truck. As a precaution, evacuations occurred both in Sandstone and Meadow Creek, WV. Dispatchers say that the container was not breached. Accordingly, evacuations for both Sandstone and Meadow Creek, WV were lifted sometime before 3:00 this morning. The driver of the truck and a driver of an SUV that was also involved in the accident were transported to Summers Appalachian Regional Hospital with unknown injuries. (State Journal August 2, 2009) [20]
  3. The tractor-trailer carried a Model 48Y cylinder containing approximately 28,000 lbs [12.7 metric tonnes] of non-enriched Uranium Hexafluoride (UF6). The shipment originated from the Honeywell Metropolis Works facility in Metropolis IL, and was being transported to Portsmouth, VA for shipment to URENCO in the Netherlands. The cab of the tractor-trailer was involved in a fire that was subsequently extinguished. The fire had no affect on the UF6 cylinder which separated from the trailer during the accident. A Honeywell team determined the cylinder sustained only minor cosmetic damage, limited to one bent lifting lug. Honeywell personnel verified that there was no visual indication of leakage, and radiation surveys confirmed that there was no contamination or leakage from the cylinder.  Download NRC Preliminary Notification PNO-II-09-004, Aug. 3, 2009 (ADAMS Acc. No. ML092150853)   [21]

7.      UF6 truck involved in accident near Paducah (Kentucky). A tractor trailer carrying enriched uranium hexaflouride has been involved in a two-vehicle crash at Paducah. There was no spill of UF6. The tractor trailer had just left the nation’s only uranium enrichment plant located in area known as “West Paducah.” It was carrying four containers holding a total of 5000 lbs of enriched uranium hexafluoride. The material was headed for the Port of Oakland in California to be shipped to an overseas customer. (AP Jan. 4 / Jan. 5, 2007) [22]

  • . On October 16, 2003, a truck carrying 4 cylinders (UX-30 design) of 5% enriched uranium in the form of uranium hexafluoride (UF6) swerved and left Highway 212 west of Broadus, Montana. The truck rolled over and came to rest on its side. Initial observations showed that the UF6 overpacks and trailer did not sustain any damage. No evidence of release of material has been observed. The material was imported through the Port of Seattle and was en route to Wilmington, North Carolina for processing. The truck driver was injured but his injuries were not life threatening. (Billings Gazette Oct. 17, 2003; NRC Morning Report Oct. 20, 2003) [23]
  • . A little after 2 p.m. on April 10, 2003, five uranium hexafluoride waste cylinders were aboard a truck that wrecked on Interstate 40 in Roane County, Tennessee. No substance was released from the cylinders due to the crash. The uranium hexafluoride cylinders were being transported from the USEC Inc.-operated uranium enrichment facility in Paducah, Ky., to Global Nuclear Fuel’s facility in Wilmington, N.C. The five cylinders in the crash were in overpacks, which is a requirement for certain types of uranium hexafluoride containers. (Oak Ridger April 11, 2003).  The accident involved UF6 cylinders that are 30 inches [76.2 cm] diameter X 7 feet [2.13 m] long and contain up to 2.5 short tons [2268 kg] solid UF6 at up to 4.95% U-235 and are known as 30B cylinders. (Jason Bolling, USEC Inc.) [24]
  1. Traffic accident involving uranium hexafluoride cylinders description. At approximately 2:00 p.m. Central Daylight Time (CDT) on April 10, 2003, a Tri-State Motor Transport tractor-trailer, carrying five 2 ½-ton cylinders of enriched uranium hexafluoride overturned in the eastbound lanes of Interstate Highway 40, approximately 20 miles west of Knoxville, Tennessee. The cylinders of uranium hexafluoride were in transit between the Paducah Gaseous Diffusion Plant, in Paducah, Kentucky and the Global Nuclear Fuels-Americas, in Wilmington, North Carolina. The accident did not result in any personal injuries, breach of any cylinders, or releases of uranium hexafluoride. Two of the transportation overpacks, used to protect each of the cylinders, were slightly damaged. […]”  (NRC, Preliminary notification of event or unusual occurrence — PNO-III-03-018, April 11, 2003) [25]
  2. Truck With “Empty” UF6 Cylinders Involved In Traffic Accident (Ohio). A truck hauling two 10-ton uranium containers was damaged on June 9, 2000 when a car ran into it on Rt. 104 near Chillicothe, Ohio, about 35 miles south of Columbus. The cylinders were empty except for residual amounts (“heels”) of natural uranium. The cylinders belong to Canadian uranium miner Cameco, which sells  uranium to USEC’s Portsmouth enrichment plant at Piketon, Ohio, which in turn enriches the uranium for use as fuel. The cylinders had been emptied at the plant and were being shipped back to Ontario. About 9 miles north of Chillicothe, the southbound car went over the center line and struck the left front tire of the northbound truck, bounced off and hit the rear tandem axle of the truck’s trailer. (The Columbus Dispatch June 10, 2000) [26]
  3. -“Portsmouth Gaseous Diffusion Plant.On June 2, 1999, two rail cars carrying depleted uranium hexafluoride (DUF6) cylinders onsite derailed while being moved several hundred yards from the cascade tails withdrawal stations to a cool-down area. Three rail cars were being pulled by a diesel track mobile unit. The track mobile unit and the first car in the train did not derail. Each rail car was carrying three 14-ton liquid DUF6 cylinders. Based on preliminary information, a defective rail tie is believed to have caused the derailment of the two rail cars. All the DUF6 cylinders remained in their rail car cradles. Plant staff assessed the derailed rail cars to be horizontally tilted at a 6 degree angle. A center-of-gravity analysis that had been previously done by the plant staff indicates that at a 34 degree horizontal tilt, the cylinders could roll out of the rail car cradles. The plant activated its Emergency Operations Center until it determined that the cylinders were in a safe condition. The plant is conducting a root-cause analysis of the incident. Region III is planning an inspection to review the incident.” (U.S. NRC Weekly Information Report For the Week Ending June 11, 1999) [27]

13.  Truck With Empty UF6 Cylinders Involved In Traffic Accident (Chicago). “On February 2, 1999, at approximately 4:30 p.m. (CST) a tractor-trailer truck loaded with 25 empty uranium hexafluoride cylinders struck an overpass on Interstate 90/94 in Chicago, Illinois. As a result of the impact, the tractor-trailer overturned, allowing seven of the cylinders to break loose from the trailer onto the interstate.” […]  “The cylinders on this shipment had been emptied, cleaned, and re-certified at the Siemens Power Corporation facility in Richland, Washington. The cylinders were en route to Harvey, Illinois, for connection to the Canadian National Railroad and eventual overseas shipment to Germany.  The cylinders were all intact after the accident and precautionary measurements taken by IDNS confirmed no release of radioactive material had occurred.” (U.S. NRC Preliminary Notification PNO-III-99-005 ) [28]

  1. Iowa). “On January 24, 1997, a flat bed trailer transporting four 2.5 ton solid uranium hexafluoride cylinders in protective overpacks, was involved in an accident on Interstate 80 in Scott County near Walcott, Iowa. The accident occurred at approximately 7:00 a.m. CST during a snow and ice storm. The truck was transporting the cylinders from the Portsmouth Gaseous Diffusion Plant to Siemens Power Corporation in Richland, Washington. All four uranium hexafluoride cylinders and their overpacks remained intact and no injuries were reported.” (U.S. NRC Preliminary Notification PNO-III-97-004 ) [29]
  2. UF6 truck crashes on A1 in the Netherlands. On May 21, 2003, a British truck carrying UF6 crashed into a Polish truck carrying paraffin on A1 (Amsterdam-Hengelo) near Bathmen, The Netherlands. The UF6 truck was part of a convoy of 12 British trucks hauling uranium hexafluoride from Preston (England) to Urenco’s enrichment plants in Almelo (The Netherlands) and Gronau (Germany). The British driver was injured. There was no leakage of UF6. (De Twentsche Courant Tubantia May 21/22, 2003) [30]

16.  Police stops uranium hexafluoride transport on rusted through flat rack at Bremen (Germany). On Mar. 8, 2010 at 11:00 h, police stopped a tractor-trailer transporting a uranium hexafluoride cylinder on the A1 motorway in Bremen. The cylinder was mounted on a flat rack with essential components rusted through. The police ordered the flat rack to be replaced, before the transport would be allowed to continue. The cylinder had arrived in the Hamburg port from the USA and was on the way to Urenco’s Gronau enrichment plant. (Pressestelle Polizei Bremen Mar. 8, 2010) [31]

17.  WECF Women in Europe for Common Future-CSD 18: Almoustapha Alhacen reports on uranium mining in Niger Accidents of uranium transports. In Niger, the conditions of security of uranium transport remain very bad, with passengers sometimes sitting on uranium barrels. In January 2004, an accident of transport resulted in 5 deaths, and radioactive material was spread on the roads. Despite repeated demands from the National Radioprotection Center of Niamey, the total decontamination was only completed one month later. [32]

18.  Highway Transport Risks and Issues. Under federal regulations, alternative routes could be designated by the states, but any alternative route designations would involve tradeoffs in terms of risk to population centers versus risks associated with the use of longer routes on two lane highways over difficult terrain and through rural communities. States actions to designate alternative routes are further complicated by a recent court decision in New Mexico which could make state and local governments liable for loss of property values along designated shipping routes.  [33]

  1. Truck shipments in the numbers needed for moving wastes to a repository from reactor sites around the nation would impact major population centers across the country and put nuclear waste trucks on the country’s interstate highways in large numbers year round for almost 3 decades. Because of the numbers of shipments involved, the chances for accidents will increase, and because the new casks will carry more waste per shipment, the consequences of a very severe accident could also increase. [34]

20.  Radiological Effects of Routine Shipments. One area of concern in nuclear waste transportation is the exposure of waste handlers, drivers, and the general public to radiation even during routine (non-accident) conditions. Even though shipping containers are shielded and designed to reduce exposures to radiation being emitted by the spent fuel or high-level waste, federal regulations allow a low level of radiation to emanate from the casks. Even after ten years of cooling, spent nuclear fuel emits dangerous levels of gamma and neutron radiation. A person standing one yard away from an unshielded spent fuel assembly could receive a lethal dose of radiation (about 500 rems) in less than three minutes. A 30 – second exposure (about 85 rems) at the same distance could significantly increase the risk of cancer and/or genetic damage. Defense high-level waste, which contains even higher concentrations of gamma-emitting fission products, is similarly dangerous. The surface dose rate of spent fuel is so great (10,000 rem/hour or more), that shipping containers with enough shielding to completely contain all emissions would be too heavy to transport economically. Federal regulations allow shipping casks to emit 10 millirems/hour at 2 meters from the cask surface, equivalent to about one chest x-ray per hour of exposure.  [35]

Between 70 and 310 transportation accidents and over 1,000 incidents would be expected over the operating life of the repository.
  1. Routine exposures become especially problematic in situations where the transport vehicle is caught in heavy traffic with cars and other vehicles in close proximity for extended periods. Routine exposures also are of concern when the cask vehicle is stopped for repair, fueling, inspections, etc.  The health effects of low level radiation are poorly understood. There is evidence that even small amounts of radiation can have long-term health implications. The potential effects of repeated exposures to large numbers of nuclear waste shipments along highways or railroads during the 25-year repository emplacement phase have not been adequately addressed and could have adverse health consequences for certain segments of the public. [36]
  2. Probability of Serious Accidents.  Between 1957 and 1964, there were 11 transportation incidents and accidents involving spent fuel shipments by the US Atomic Energy Commission and its contractors.  Several of these incidents resulted in radioactive releases requiring cleanup, including leakage from a rail cask in 1960 and leakage from a truck cask in 1962. There is no comparable data for the period from 1964 to 1970, when utility shipments to reprocessing facilities began. Between 1971 and 1990, there were six accidents and 47 incidents involving spent fuel cask shipments. Three accidents (two truck, one rail) involved casks loaded with spent fuel. No radioactivity was released in these accidents. Most of the incidents involved excess radioactive contamination on cask surfaces, a result of the so-called “weeping” phenomena on casks loaded and unloaded in wet storage pools. [37]
  3. Based on the 1971-1990 accident data, DOE calculated accident and incident rates for commercial spent fuel shipments to a repository. For truck shipments, DOE calculated O.7 accidents and 10.5 incidents per million shipment miles. For rail shipments, DOE calculated 9.7 accidents and 19.4 incidents per million shipment miles. Because of the small number of spent fuel shipments and accidents during these years, DOE compared these accident/incident rates to the general accident rates for large commercial trucks and general rail freight movements. Based on this analysis, DOE concluded that accident rates for general truck and rail transportation should be used in repository transportation risk and impact studies. DOE recommended use of a truck accident rate of 0.7 – 3.0 accidents per million shipment miles and a rail accident rate of 11.9 accidents per million shipment miles. [38]
  4. An estimate of the number of accidents likely to occur during spent fuel shipments to a repository can be obtained by multiplying the anticipated accident rates by the anticipated cumulative shipment miles. If all spent fuel were to be shipped to the repository by truck in larger-capacity casks, requiring about 46,000 shipments and over 100 million shipment miles, between 70 and 310 accidents and over 1,000 incidents would be expected over the operating life of the repository. Under the DOE base case scenario (88% rail, 12% truck), about 50 to 260 accidents and 250 to 590 incidents would be expected. [39]
Release of only a small fraction of shipping cask’s contents would be sufficient to contaminate a 42 square mile area and cost over $620 million to cleanup.
  1. Both DOE and Nevada researchers have looked at the potential for a worst-case accident to occur. While there is disagreement over the specifics of a credible worst-case occurrence, there is agreement that such an accident would involve the release of some of the radioactive material inside the shipping cask.  [40] 
  2. A 1985 DOE contractor report concluded that a maximum severe, credible accident involving a single, current-generation rail cask could result in release of radioactive materials to the environment. The study assumed a severe impact followed by a massive fire fed by large quantities of fuel. According to the study, release of only a small fraction (1380 curies) of the cask’s contents would be sufficient to contaminate a 42 square mile area. [41]
  3. The costs of cleanup after such an accident would exceed $620 million, and the cleanup effort would require 460 days, if it occurred in a rural area. An alternative analysis by an Agency contractor estimated cleanup costs for the same rural accident ranging from $176 million to $19.4 billion, depending primarily upon permissible post-accident soil concentrations of cobalt-60, cesium-134, and cesium-137, and upon regulatory requirements for disposal of the contaminated soil. Cleanup after a similar accident in a typical urban area would be considerably more expensive and time consuming (perhaps $9.5 billion just to raze and rebuild the most heavily contaminated square mile or so). Much more detailed studies are necessary to estimate accident cleanup costs for a specific urban location in metropolitan Las Vegas or elsewhere in Nevada. [42]

[1] Eichstaedt 109

[2] McSwain, 2007

[3] deLemos, 2007 

[4] Ibid 29, 53

[5] Doug Brugge 95

[6] Institute for Energy and Environmental Research

[7] EPA 02, 2008 

[8] EPA02, 2008

[9] South West Research Institute, 2010

[10] Pasternak, 2006

[11] Indian Health Services data

[12] Smith, 2008 & Ralorr 2004

[13] AP June 16, 2010

      [14] Court Opinion June 15, 2010, Case No. 07-9506 (PDF), Hydro Resources, Inc. v. United States Environmental Protection Agency

[15] http://web.ead.anl.gov/uranium/faq/health/faq36.cfm

[16] http://www.bbc.co.uk

[17] Testimony of Forgotten People to the Subcommittee on National Parks and Public Lands of the Committee on Natural Resources Community Impacts of Mining Near Grand Canyon National Park, April 23, 2010

[18] ibid at 2

[19]http://www.denisonmines.com/SiteResources/data/MediaArchive/pdfs/WhiteMesaMill/ore%20transport%20policy%20for%20ore%20purchase%20(final).pdf

4. Transport Accidents, http://www.wise-uranium.org/etiss.html#ACCID

[21] ibid at 4

[22] ibid at 4

[23] ibid at 4

[24] ibid at 4

[25] ibid at 4

[26] ibid at 4

[27] ibid at 4

[28] ibid at 4

[29] ibid at 4

[30] ibid at 4

[31] ibid at 4

[32] 21.05.2010 | WECF Report  http://www.wecf.eu/english/articles/2010/05/almahacen-csd.php

[33] ibid at 19

[34] http://www.state.nv.us/nucwaste/trans/trfact03.htm

[35] ibid at 18

[36] ibid at 18

[37] ibid at 18

[38] ibid at 18

[39] ibid at 18

[40] ibid at 18

[41] ibid at 18

[42] ibid at 18