August 12, 2016:
COMPLAINT FOR DECLARATORY AND ADMINISTRATIVE RELIEF, PRELIMINARY AND PERMANENT INJUNCTIONS;
Exhibit A (February 27, 2013 public comment letter, to DOE, Re: Need for New Environmental Impact Statement (EIS) on the Unprecedented Import from Canada to the Savannah River Site of Liquid High-Level Waste Containing Highly Enriched Uranium (HEU); Possible Programmatic EIS Needed if Shipments from Other countries are being Eyed);
Exhibit B (March 2013 Supplement Analysis, by Savannah River Site, Spent Nuclear Fuel Management, U.S. Department of Energy, Office of Environmental Management, Savannah River Operations Office, Aiken, South Carolina; DOE/EIS-0279-SA-01 and DOE/EIS-0218-SA-06);
Exhibit C (Amended Record of Decision (ROD), March 29, 2013, U.S. Department of Energy (DOE), Spent Nuclear Fuel Management at the Savannah River Site, David Huizenga, Senior Advisor for Environmental Management [FR Doc. 2013–07994 Filed 4–4–13; 8:45 am], Federal Register, Vol. 78, No. 76, Friday, April 5, 2013, Notices, pages 20625 to 20628);
Exhibit D (Rep. Higgins letter to Secretary Moniz, July 16, 2014; U.S. Congressman Brian Higgins (D-NY-26), Committee on Homeland Security, Ranking Member, Subcommittee on Counterterrorism and Intelligence, to Ernest Moniz, Secretary, U.S. Department of Energy);
Exhibit E (AG Schneiderman letter to Secretary Moniz, July 25, 2014; State of New York Attorney General Eric T. Schneiderman, letter to Ernest Moniz, Secretary, U.S. Department of Energy);
Exhibit F (DOE/EIS-0218-SA-07, Supplement Analysis for the Foreign Research Reactor Spent Nuclear Fuel Acceptance Program, Highly Enriched Uranium Target Residue Material Transportation, U.S. Department of Energy, November 2015).