ML25346A278

San Antonio Bay Estuarine Waterkeepers Motion to Amend Contention 4 Based on Er Supplement 2

ML25346A278
Person / Time
Site:	05000614
Issue date:	12/12/2025
From:	Perales M Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 57554, ASLBP 25-991-01-CP-BD01, 50-614-CP
Download: ML25346A278 (0)

Text

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

Long Mott Energy, LLC (Long Mott Generating Station)

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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 December 12, 2025 SAN ANTONIO BAY ESTUARINE WATERKEEPERS MOTION TO AMEND CONTENTION 4 BASED ON ER SUPPLEMENT 2 Pursuant to 10 C.F.R. § 2.309(c), San Antonio Bay Estuarine Waterkeeper (Waterkeeper or Petitioner) submits this Motion to Amend Contention 4, by which it seeks leave to amend a portion of Contention 4 in its August 11, 2025 Petition to Intervene and Request for Hearing, based on Long Mott Energy, LLCs (LME) Supplement 2 to its Environmental Report (ER).

I.

INTRODUCTION The Boards August 28, 2025 Initial Prehearing Order set the deadline for filing new/amended contentions within 30 days of the date upon which the information that is the basis of the motion becomes available to the petitioner/intervenor. LME submitted Supplement 2 to its ER by cover letter dated October 17, 2025 (ML25290A123). The Supplement was added to the Commissions ADAMS Public Search database on October 27, 2025. Accordingly, the original deadline for filing a new/amended contention based on this Supplement was November 26, 2025.

2 However, as discussed in the Boards October 1, 2025 and November 13, 2025 Orders, due to the lapse in government funding, all filing deadlines affected by the shutdown... have been extended by 43 days. Because the deadline to file a new or amended contention based on Supplement 2 to the ER accrued during the government shutdown, Waterkeeper has conservatively tolled it by sixteen dayswhich is the difference between ER Supplement 2s availability on ADAMS and the end of the government shutdown. This makes the new deadline December 12, 2025. Therefore, this filing is timely.

By this Motion, Waterkeeper seeks to amend a portion of its Contention 4, based on LMEs ER Supplement 2. As explained below, Waterkeeper maintains that ER Supplement 2 does not resolve the portion of Waterkeepers Contention 4 that addressed LMEs failure to conduct the required assessment of the impacts of continued storage of spent nuclear fuel beyond the licensed lifetime of the reactor; nor does ER Supplement 2 justify LMEs erroneous reliance on 10 C.F.R. § 51.23 and NUREG-2157 (General Environmental Impact Statement for Continue Storage of Spent Nuclear Fuel) in lieu of conducting the required assessment. LMEs reference, in its ER Supplement 2, to the high temperature gas-cooled reactor at Fort Saint Vrain does not absolve LME from the requirement that it assess the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed life for operation of a reactor, or seek an exemption.

II.

CONTENTION 4 In its August 11, 2025 Petition to Intervene and Request for Hearing, Waterkeeper maintained in Contention 4 that LME failed to conduct the required assessment of the

3 impacts of continued storage of spent nuclear fuel beyond the licensed lifetime of the reactor.1 Waterkeeper also explained that LMEs references to 10 C.F.R. § 51.23 and NUREG-2157 (GEIS) were inapposite because they only apply to light-water reactors, not non-light-water reactors, such as the one proposed by LME.

In their Answer to Waterkeepers Petition, the NRC Staff indicated that in their estimation, this part of Contention 4 was admissible; NRC Staff characterized it as a contention of omission.2 NRC Staff explained that [a]n applicant not covered by the Continued Storage GEIS can rely on it, if the applicant demonstrates that the Continued Storage GEISs analysis bounds the proposed facility.3 The Staff also stated that LME did not include supporting analysis for its statement that [w]aste and spent fuel inventories, as well as their associated certified spent fuel shipping and storage containers are not significantly different from what has been considered for LWR evaluations in [the Continued Storage GEIS].4 LME, on the other hand, claimed that assessment [of the impacts of continued storage of spent nuclear fuel beyond the licensed lifetime of the reactor] clearly is not omitted from the ER.5 A.

LMEs Supplement 2 to the ER LMEs Supplement 2 to the ER, Confirmatory Information Regarding the Environmental Report for the Long Mott Generating Station Construction Permit 1 Waterkeepers Petition, pp. 49-50.

2 NRC Staff Answer, pp. 39-42.

3 NRC Staff Answer, p. 41.

4 Id.

5 LME Answer, p. 93.

4 Application, provides that [t]he fuel kernels used by the Xe-100 at LMGS will be comparable to those used by the HTGR at Fort St. Vrain,6 but fails to explain the basis for this statement or how this statement excuses LME from compliance with the requirement that it assess the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed life for operation of a reactor.

Nonetheless, the NRC Staff indicated, via their Notification Regarding Supplemental Information dated December 3, 2025, that because the information supplied by LME in its ER Supplement 2 explains how the Continued Storage GEIS bounds its fuel and its application, LMEs supplemental submission appears to be sufficient to moot the portion of Contention 4 related to the environmental effects of continued storage of spent fuel generated by Long Mott Generating Station.7 NRC Staff also indicated, in that same Notification, that Staffs review is ongoing and it takes no position on the merits of LMEs supplemental information at this time.8 As explained more fully below, Waterkeeper maintains that Supplement 2 to the ER does not resolve the concerns raised in its Petition. An attached Declaration by Dr. Edwin Lyman offers support for Waterkeepers proposed amendment to its Contention 4. In it, Dr. Lyman explains why ER Supplement 2 does not remedy or resolve LMEs failure to demonstrate compliance with the requirement that it assess the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed life for operation of a 6 LME ER, Supp. 2, pdf p. 4.

7 NRC Staff Notification Regarding Supplemental Information, pdf p. 3 (Dec. 3, 2025).

8 NRC Staff Notification Regarding Supplemental Information, pdf p. 3 (Dec. 3, 2025).

5 reactor. He further explains why the fuel kernels LME proposes to use at the Long Mott Generating Station are not comparable to the spent fuel stored at Fort Saint Vrain, and consequently, why LMEs statement to the contrary in its ER Supplement 2 is not accurate.9 Accordingly, Waterkeeper seeks to amend its Contention 4 to explain why ER Supplement 2 and LMEs reference to the high temperature gas-cooled reactor at Fort Saint Vrain does not resolve Waterkeepers critiques regarding its failure to assess the environmental impacts of continued storage of the spent nuclear fuel.

B.

Waterkeepers Amended Contention & Basis Statement Waterkeepers proposed amended contention remains mostly the same as its initial Contention 4 on the issue of LMEs failure to assess the environmental impacts of continued storage of spent nuclear fuel,10 except that Waterkeeper now seeks to explain why ER Supplement 2 does not satisfy this requirement and does not justify LMEs reliance on the Continued Storage GEIS to satisfy this requirement. That is, Waterkeeper maintains that LMEs ER Supplement 2 is inadequate to satisfy applicable requirements related to LMEs proposed continued storage of spent nuclear fuel beyond the licensed lifetime of the reactor. This amended contention is supported by the attached Declaration of Dr. Lyman.

9 Dr. Lyman Declaration, Enclosure A.

10 See Waterkeepers Petition, pp. 49-50 (referencing 10 C.F.R. § 51.23 and NUREG-2157 (GEIS for Continued Storage of Spent Nuclear Fuel)).

6 In its ER Supplement 2, LME contends that [t]he fuel kernels used by the Xe-100 at LMGS will be comparable to those used by the HTGR at Fort St. Vrain,11 without any explanation or analysis in support of this conclusory statement. The implication is that (1) because the Fort Saint Vrain on-site spent fuel storage is within the scope of the GEIS12 and (2) because LME concludes that fuel kernels used by the Xe-100 at LMGS will be comparable to those used by the HTGR at Fort St. Vrain, LMEs reliance on the GEIS is an acceptable method for LME to demonstrate compliance with the requirement that it assess the environmental impacts of its proposed storage of spent nuclear fuel.

But, as Dr. Lyman explains in his Declaration, the fuel kernels to be used by the Xe-100 at the Long Mott Generating Station are significantly different than those used at Fort Saint Vrain, rendering them incomparable.13 Also, the spent nuclear fuel that the Long Mott Generating Station is projected to generate will be different than the spent nuclear fuel generated by Fort Saint Vrain in ways that could reasonably be expected to lead to greater environmental impacts for long-term storage.14 Dr. Lyman emphasizes that [o]n this basis alone, the spent fuel stored at the proposed Long Mott Generating Station could have significantly different characteristics that would have an impact on its performance in long-term storage.15 To illustrate the differences, Dr. Lyman explains in his Declaration that the assumed maximum burnup of the spent TRISO fuel in the Fort St. Vrain Independent 11 LME ER, Supp. 2, pdf p. 4.

12 NUREG-2157 (GEIS for Continued Storage of Spent Nuclear Fuel), at p. 2-10.

13 Enclosure A, Dr. Lymans Declaration, p. 3.

14 See Attached Enclosure A, Dr. Lymans Declaration, pp. 3-5.

15 Enclosure A, Dr. Lymans Declaration, p. 4.

7 Spent Fuel Storage Installation is 111 GWd/MTU lower than the proposed Long Mott Generating Stations stated average end of life burnup for HALEU pebbles.16 A consequence of this is that the higher burnup of the LME pebbles would have an impact on the magnitude and distribution of the decay heat throughout the fuel elements, the fission product content, the actinide content, the fission gas content, and the irradiation damage of the uranium kernels, TRISO coatings, and graphite matrix. It would also have an impact on the external radiation field.17 In sum, not only did LME fail to offer any support for its conclusory statement, in its ER Supplement 2, that fuel kernels used by the Xe-100 at LMGS will be comparable to those used by the HTGR at Fort St. Vrain, but this statement is inaccurate in important ways. As explained above and in Dr. Lymans Declaration, the fuel from the two facilities is significantly different, rendering them incomparable. Accordingly, LMEs ER Supplement 2 does not justify LMEs attempt to rely on NUREG-2157 (GEIS for Continued Storage of Spent Nuclear Fuel) to demonstrate compliance with the requirement that it assess the environmental impacts of continued storage of spent nuclear fuel beyond the licensed lifetime of the reactor. That is, ER Supplement 2 does not demonstrate that the Continued Storage GEIS bounds the LME facility, its fuel, or its application. LME is not relieved from the requirement that it assess the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed life for operation of a reactor, in this CPA proceeding.

16 Enclosure A, Dr. Lymans Declaration, p. 4 (emphasis added).

17 Enclosure A, Dr. Lymans Declaration, pp. 4-5.

8 III.

Good cause exists for this filing.

Waterkeeper respectfully submits that it satisfies the good cause standard in 10 C.F.R. § 2.309(c)(i)-(iii) for its Amended Contention. LMEs ER Supplement 2 is new and materially different from what was presented in the original ER, as discussed above.

Indeed, the Staff continues to review the adequacy of Supplement 2, though they have already changed their position regarding Waterkeepers Contention 4 based on LMEs statement that fuel kernels used by the Xe-100 at [Long Mott Generating Station] will be comparable to those used by the [high temperature gas-cooled reactor] at Fort St. Vrain.

This filing is being submitted in a timely fashion. As explained above, LMEs ER Supplement 2 was not available until October 27, 2025. Accordingly, the original deadline for filing a new/amended contention based on this Supplement was November 26, 2025.

However, as discussed in the Boards October 1, 2025 and November 13, 2025 Orders, due to the lapse in government funding, all filing deadlines affected by the shutdown... have been extended by 43 days. Because the deadline to file a new or amended contention based on Supplement 2 to the ER accrued during the government shutdown, Waterkeeper has tolled it by sixteen dayswhich is the difference between the availability on ADAMS of ER Supplement 2 and the end of the government shutdown. This makes the new deadline December 12, 2025. Therefore, this filing is timely.

IV.

CONCLUSION

9 For the foregoing reasons, Waterkeepers Motion to Amend Contention 4 Based on ER Supplement 2 should be granted.

Date: December 12, 2025 Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.

1206 San Antonio St.

Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)

Counsel for San Antonio Bay Estuarine Waterkeeper

10 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

Long Mott Energy, LLC (Long Mott Generating Station)

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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 December 12, 2025 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on December 12, 2025, copies of the foregoing San Antonio Bay Estuarine Waterkeepers Motion to Amend Contention 4 Based on ER Supplement 2 were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned docket.

Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.

1206 San Antonio St.

Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)

Counsel for San Antonio Bay Estuarine Waterkeeper

ENCLOSURE A

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

Long Mott Energy, LLC (Long Mott Generating Station)

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§ Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 December 12, 2025 DECLARATION OF EDWIN LYMAN, Ph.D. IN SUPPORT OF MOTION TO AMEND CONTENTION 4 BASED ON ER SUPPLEMENT 2 I, Dr. Edwin Lyman, declare as follows:

1. My name is Edwin Lyman. I am over eighteen (18) years of age and of sound mind, have never been convicted of a felony, and am otherwise capable of making this declaration. The information in this declaration is based on my personal experience and my review of documents filed in this proceeding and publicly available information.

Background

2. I am the Director of Nuclear Power Safety at the Union of Concerned Scientists (UCS) in Washington, DC, and I have been employed at UCS since 2003. I earned a doctorate degree in physics from Cornell University in 1992. I have over three decades of experience in nuclear power safety and security, working as a postdoctoral research associate at Princeton Universitys Center for Energy and Environmental Studies (now the Science and Global Security Program) and serving as the president of the Nuclear Control Institute before I joined UCS. I have published articles and letters regarding those issues in journals and magazines including Science, Nature, The Bulletin of the Atomic Scientists, Science and Global Security, Arms Control Today, Nuclear Engineering International, New Scientist and Energy and Environmental Science. I am a co-author (with David Lochbaum and Susan Q. Stranahan) of the book Fukushima:

The Story of a Nuclear Disaster (The New Press, 2014). I am a member of the Institute

Declaration of Edwin Lyman, Ph.D.

Page 2 of Nuclear Materials Management and the American Nuclear Society, and I have testified before Congress and the Nuclear Regulatory Commission and published articles in several journals and magazines about nuclear power. In 2018 I was awarded the Leo Szilard Lectureship Award from the American Physical Society for my work on nuclear safety and security. I have also served as a qualified expert witness for intervenors in several NRC adjudicatory proceedings. From 2020-2023, I served on a National Academies committee that studied advanced reactor fuel cycles and wastes, including high-temperature gas-cooled reactors. A copy of my curriculum vitae is attached as Enclosure A-1.

Review of Long Mott Energy, LLCs Application

3. I have been engaged as a technical consultant by San Antonio Bay Estuarine Waterkeeper (Waterkeeper) for purposes of reviewing the Long Mott Generating Stations (Long Mott) Construction Permit Application (CPA or LM-CPA) and identifying issues of concern that may be relevant to Waterkeeper and its members.

4. To that end, I have reviewed Long Motts CPA. I am familiar with and have reviewed applicable NRC regulations, policies, and guidance documents.

5. I assisted Waterkeeper with the preparation of Contention 1, which addresses the adequacy of LM-CPAs proposed functional containment.

6. I also assisted Waterkeeper with the preparation of its Motion to Amend Contention 4 Based on ER Supplement 2, which addresses LMEs failure to demonstrate how the Continued Storage GEIS bounds its fuel and its application through Supplement 2 to the ER.

Contention 4 and ER Supplement 2

7. Based on my professional judgment and my review of the LM-CPA, relevant NRC regulations and guidance documents, and documents filed in this proceeding, it is my opinion that LME has failed to demonstrate that the Continued Storage GEIS analysis

Declaration of Edwin Lyman, Ph.D.

Page 3 bounds the proposed facility through Supplement 2 to the ER. An explanation of the bases for my opinion is detailed below.

8. On October 17, 2025, LME responded to NRC Staff information needs related to the environmental report. LME provided that the fuel kernels used by the Xe-100 at [Long Mott Generating Station] will be comparable to those used by the [high temperature gas-cooled reactor] at Fort St. Vrain.

9. In its December 3, 2025 Notification Regarding Supplemental Information, the NRC Staff concluded, [T]he information supplied by LME in its October 17 submittal explains how the Continued Storage GEIS bounds its fuel and its application.

However, for the below reasons, this conclusion is not supported by the information supplied by LME.

10. First, the fuel kernels to be used by the Xe-100 at the Long Mott Generating Station would not be comparable to those used at Fort St. Vrain. Second, the spent nuclear fuel that the Long Mott Generating Station is projected to generate will be different than the spent nuclear fuel generated by Fort St. Vrain in ways that could lead to greater environmental impacts for long-term storage.

11. The LME fuel kernels will be composed of uranium oxycarbide (UCO) with a uranium enrichment of 15.5 weight percent.1 In contrast, the Fort St. Vrain fuel kernels were composed of fissile particles containing a mixture of uranium and thorium carbides with a uranium enrichment of 93 percent and fertile particles containing only thorium carbide.2

12. The LME fuel elements will be in pebble form,3 whereas the Fort St. Vrain fuel elements are in the form of prismatic compacts. The upper manufacturing limit for the uranium content of Fort St. Vrain fuel elements was 1.374 grams,4 compared to 7 grams 1 LM-CPA Environmental Report, 3.2 - 2.

2 Fort St. Vrain Independent Spent Fuel Storage Installation, Safety Analysis Report, Rev. 8, Chapter 3 -

Principal Design Criteria (2010) (ML103640368), at 3-2 (hereinafter FSV ISFSI SAR).

3 LM-CPA Environmental Report, 3.2 - 2.

4 FSV ISFSI SAR at 3-24.

Declaration of Edwin Lyman, Ph.D.

Page 4 for a LME pebble.5 Also, the Fort St. Vrain spent fuel encompasses a large number of different fuel element designs (the initial core had 67 different types of fuel elements).6 These differences could have a significant impact on the physical characteristics and storage performance of the Fort St. Vrain spent fuel compared to the LME spent fuel.

13. The maximum burnup of a batch of discharged spent fuel from a nuclear reactor core is greater than the average burnup of spent fuel due to variations in power and core residence time, among other factors. This is true for both prismatic-core and pebble-bed high temperature gas-cooled reactors.7

14. The maximum burnup of the spent TRISO fuel stored at the Fort St. Vrain Independent Spent Fuel Storage Installation facility is assumed to be 52 gigawatt-days per metric ton uranium (GWd/MTU). The actual core-averaged burnup has been estimated at 38.7 GWd/MTU.8

15. The LM-CPA provides that [t]he average end of life burnup for [High-Assay Low-Enriched Uranium (HALEU)] pebbles during full power equilibrium core conditions is approximately 163 GWd/MTU.9

16. The assumed maximum burnup of the spent TRISO fuel in the Fort St. Vrain Independent Spent Fuel Storage Installation is 111 GWd/MTU lower than the proposed Long Mott Generating Stations stated average end of life burnup for HALEU pebbles.

17. On this basis alone, the spent fuel stored at the proposed Long Mott Generating Station could reasonably be expected to have significantly different characteristics that would have a significant impact on its performance in long-term storage.

18. For example, the higher burnup of the LME pebbles would have an impact on the magnitude and distribution of the decay heat throughout the fuel elements, the fission 5 LM-CPA Environmental Report, 3.2 - 2.

6 FSV ISFSI SAR at 3-3.

7 See Fanny Vitullo et al., Statistical Burnup Distribution of Moving Pebbles in the High Temperature Reactor HTR-PM, 6 J. Nuclear Engg and Radiation Sci. 021108-1 (April 2020), at 021108-1.

8 See FSV ISFSI SAR at 3-3.

9 LM-CPA Environmental Report, 3.2 - 2.

Declaration of Edwin Lyman, Ph.D.

Page 5 product content, the actinide content, the fission gas content, and the irradiation damage of the uranium kernels, TRISO coatings, and graphite matrix. It would also have an impact on the external radiation field. The impact of the greater uranium loading and physical form of the LME pebbles compared to that of the Fort St. Vrain prismatic fuel elements would also have effects on the predicted spent fuel properties that would require evaluation.10

19. Given these effects, LME has failed to demonstrate how the Continued Storage GEIS bounds its fuel and its application through Supplement 2 to the ER. Reference to the high temperature gas-cooled reactor at Fort St. Vrain does not remedy this erroneous reliance on the Continued Storage GEIS.

20. Therefore, LME is not relieved from the requirement that it address the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed life for operation of a reactor.

Declaration Signature

21. My name is Edwin Lyman, my date of birth is June 21, 1964, and my address is 1825 K Street NW, Suite 800, Washington, District of Columbia, 20006, USA. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed on the 12th day of December, 2025, in accordance with 10 C.F.R. § 2.304(d).

Signed (electronically) by Edwin Lyman Edwin Lyman, Ph.D.

Director of Nuclear Power Safety Union of Concerned Scientists 1825 K St. NW, Ste. 800 Washington, DC 20006 ELyman@ucs.org 202-331-5445 10 See Gordon M. Petersen et al., Preliminary Analysis of Advanced Reactors Storage, Transportation, and Disposal, INL/CON-23-75963-Revision-0 (March 2024), at 5 (Characteristics and Properties of TRISO SNF).

ENCLOSURE A-1

Edwin Stuart Lyman 1825 K St. NW, Ste. 800, Washington, DC 20006 202-331-5445; ELyman@ucs.org Education Ph.D., Cornell University, Physics, August 1992.

M.S., Cornell University, Physics, January 1990.

A.B., summa cum laude, New York University, Physics, June 1986; Phi Beta Kappa.

Professional Experience January 2020 - Present: Director of Nuclear Power Safety, Union of Concerned Scientists, Washington, D.C.

May 1, 2003 - January 2020: Senior Scientist, Global Security Program, Union of Concerned Scientists, Washington, D.C.

Spring 2015: Adjunct Professor, Elliott School of International Affairs, The George Washington University, Washington, DC. Taught Masters level course on nuclear energy.

June 2002 - April 2003: President, Nuclear Control Institute, Washington, D.C.

July 1995 - May 2002: Scientific Director, Nuclear Control Institute, Washington, D.C.

August 1992 - June 1995: Postdoctoral research associate, Center for Energy and Environmental Studies, Princeton University, Princeton, NJ.

Spring 1994: Lecturer, Woodrow Wilson School, Princeton University. Preceptor for "Science, Technology and Public Policy."

July 1988 - June 1992: Graduate research assistant, Newman Laboratory of Nuclear Studies, Cornell University, Ithaca, NY. Conducted thesis research on high-energy physics.

August 1986-June 1988: Andrew D. White Graduate Fellow, Physics, Cornell University.

Awards 2018 Leo Szilard Lectureship Award, American Physical Society.

Awarded annually to recognize outstanding accomplishments by physicists in promoting the use of physics for the benefit of society in such areas as the environment, arms control, and science policy.

Other Maintains UCS Nuclear Safety Project X account: @NucSafetyUCS Held Nuclear Regulatory Commission L clearance (administratively withdrawn in 2019)

2 Books and Book Chapters National Academies of Sciences, Engineering, and Medicine. Merits and Viability of Different Nuclear Fuel Cycles and Technology Options and the Waste Aspects of Advanced Nuclear Reactors. The National Academies, Washington D.C., 2023.

D. Lochbaum, E. Lyman and S.Q. Stranahan. Fukushima: The Story of a Nuclear Disaster. The New Press, New York, 2014.

E. Lyman, Nuclear Energy and Human Health, Encyclopedia of Environmental Health. Elsevier Science, 2011.

E. Lyman, Can Nuclear Fuel Production in Iran and Elsewhere be Safeguarded Against Diversion? in Falling Behind: International Scrutiny of the Peaceful Atom (H.D. Sokolski, ed.).

Strategic Studies Institute, U.S. Army War College, 2008, 101-120.

E. Lyman and D. Lochbaum, Protecting Vital Targets: Nuclear Power Plants, in Homeland Security: Protecting Americas Targets, Vol. III (J. Forest, ed.). Praeger, Westport, CT, 2006, 157-173.

E. Lyman, "The Limits of Technical Fixes," in Nuclear Power and The Spread of Nuclear Weapons: Can We Have One Without the Other?" (P. Leventhal, S. Tanzer and S. Dolley, eds.).

Brassey's, Washington, DC, 2002, 167-182.

Journal Articles and Letters R. S. Kemp, E. S. Lyman, M. R. Deinert, R. L. Garwin, and F. N. von Hippel, The Weapons Potential of High-Assay Low-Enriched Uranium. Science 384 (2024), 1071-1073.

E. Lyman, Nuclear Power is Not Clean or Safe Enough, The Environmental Forum, March/April 2024, 59.

E. Lyman, Aging Nuclear Plants, Industry Cost-Cutting, and Reduced Safety Oversight: A Dangerous Mix, Bulletin of the Atomic Scientists online, August 29, 2019.

E. Lyman, The Pentagon Wants to Boldly Go Where No Nuclear Reactor Has Gone Before. It Wont Work, Bulletin of the Atomic Scientists online, February 2019.

E. Lyman, Advanced Reactors: Proliferation and Terrorism Concerns, Physics and Society, American Physical Society, October 2018.

E. Lyman, M. Schoeppner, and F. von Hippel, Nuclear Safety Regulation in the Post-Fukushima Era, Science 356 (2017), 808-809.

3 E. Lyman and F. von Hippel, Nuclear Waste: Weapons Plutonium Riskier Above Ground (letter),

Nature 530 (2016), 281.

T. Clements, E. Lyman and F. von Hippel, The Future of Plutonium Disposition, Arms Control Today, June/July 2013.

J. Beyea, E. Lyman and F. von Hippel, Accounting for Long-Term Doses in "Worldwide Health Effects of the Fukushima Daiichi Nuclear Accident, Energy and Environmental Science 6 (2013),

1042-1045.

E. Lyman, Rotblats Pursuit of Nuclear Peace, New Scientist, January 25, 2012.

E. Lyman, Surviving the One-Two Nuclear Punch. Bulletin of the Atomic Scientists online, September 2011.

E. Lyman, Security Since September 11th, Nuclear Engineering International, May 20, 2010.

E. Lyman, Thirty Years after TMI: Five Continuing Vulnerabilities, Bulletin of the Atomic Scientists, March 23, 2009.

E. Lyman, Making Domestically Produced Medical Isotopes a National Priority, Bulletin of the Atomic Scientists, December 18, 2008.

E. Lyman, Can Nuclear Plants be Safer? Bulletin of the Atomic Scientists, September/October 2008, 34-37.

E. Lyman and F. von Hippel, Reprocessing Revisited: The International Dimensions of the Global Nuclear Energy Partnership, Arms Control Today, April 2008, 6-14.

J. Beyea, E. Lyman and F. von Hippel, Damages from a Major Release of 137Cs Into the Atmosphere of the United States, Science and Global Security 12 (2004) 125-136.

G. Bunn, C. Braun, A. Glaser, E. Lyman and F. Steinhausler, "Research Reactor Vulnerability to Sabotage by Terrorists," Science and Global Security 11 (2003)85-107.

D. Hirsch, D. Lochbaum and E. Lyman, The NRCs Dirty Little Secret, Bulletin of the Atomic Scientists (May/June 2003).

R. Alvarez, J. Beyea, K. Janberg, J. Kang, E. Lyman, A. Macfarlane, G. Thompson and F. von Hippel, Reducing the Hazards from Stored Spent Power-Reactor Fuel in the United States, Science and Global Security 11 (2003) 1-51.

E. Lyman, "Revisiting Nuclear Power Plant Safety" (letter), Science 299 (2003), 202.

4 E. Lyman, "The Pebble-Bed Modular Reactor: Safety Issues," Physics and Society, American Physical Society, October 2001.

E. Lyman, "Public Health Risks of Substituting Mixed-Oxide for Uranium Fuel in Pressurized Water Reactors," Science and Global Security 9 (2001), 1.

E. Lyman and S. Dolley, "Accident Prone," Bulletin of the Atomic Scientists, March/April 2000, 42.

E. Lyman and H. Feiveson, "The Proliferation Risks of Plutonium Mines," Science and Global Security 7 (1998), 119.

E. Lyman and P. Leventhal, "Bury the Stuff [Weapons Plutonium]," Bulletin of the Atomic Scientists, March/April 1997, 45.

E. Lyman, "Weapons Plutonium: Just Can It," Bulletin of the Atomic Scientists, November/December 1996, 48.

F. von Hippel and E. Lyman, "Appendix: Probabilities of Different Yields," addendum to J. Mark, "Explosive Properties of Reactor-Grade Plutonium," Science and Global Security 4 (1993), 125.

F. Berkhout, A. Diakov, H. Feiveson, H. Hunt, E. Lyman, M. Miller, and F. von Hippel, "Disposition of Separated Plutonium," Science and Global Security 3 (1993), 161 E. Lyman, F. Berkhout and H. Feiveson, "Disposing of Weapons-Grade Plutonium," Science 261 (1993) 813.

P. Argyres, E. Lyman and S.H.-H. Tye, "Low-Lying States of the Six-Dimensional Fractional Superstring," Phys. Rev. D46 (1992) 4533.

S.-w. Chung, E. Lyman and S.H.-H. Tye, "Fractional Supersymmetry and Minimal Coset Models in Conformal Field Theory," Int. J. Mod. Phys A7 (1992) 3337.

Selected Reports E. Lyman, Preventing an American Fukushima, Union of Concerned Scientists, March 2016.

E. Lyman, Excess Plutonium Disposition: The Failure of MOX and the Promise of Its Alternatives, Union of Concerned Scientists, December 2014.

E. Lyman, Small Isnt Always Beautiful: Safety, Security and Cost Concerns About Small Modular Reactors, Union of Concerned Scientists, September 2013.

5 D. Lochbaum and E. Lyman, U.S. Nuclear Power Safety One Year After Fukushima, Union of Concerned Scientists, March 2012.

L. Gronlund, D. Lochbaum and E. Lyman, Nuclear Power in a Warming World, Union of Concerned Scientists, December 2007.

E. Lyman (with M. Schneider et al.), Residual Risk: An Account of Events in Nuclear Power Plants Since the Chernobyl Accident in 2006, commissioned by the Greens of the European Parliament, May 2007.

E. Lyman, Chernobyl on the Hudson? The Health and Environmental Impacts of a Terrorist Attack at the Indian Point Nuclear Power Plant, commissioned by Riverkeeper, Inc., September 2004.

E. Lyman, "Safety Issues in the Sea Shipment of Vitrified High-Level Radioactive Wastes to Japan,"

report sponsored by the Nuclear Control Institute, Greenpeace International and Citizens' Nuclear Information Center Tokyo, December 1994.

E. Lyman, "Interim Storage Matrices for Excess Plutonium: Approaching the 'Spent Fuel Standard' Without the Use of Reactors," PU/CEES Report No. 286, Center for Energy and Environmental Studies, Princeton University, August 1994.

E. Lyman, "The Solubility of Plutonium in Glass," PU/CEES Report No. 275, Center for Energy and Environmental Studies, Princeton University, April 1993.

Selected Invited Talks and Testimony Dry Cask Sabotage: Outlier Events, presentation at the San Onofre Community Engagement Panel meeting on Outlier Events and Response Strategies, May 28, 2020.

Testimony on U.S. commercial nuclear reactor safety and security before the Senate Committee on Environment and Public Works, November 13, 2019.

UCS Perspectives on Accident Tolerant Fuel Technologies and Licensing Process, presentation at NRC Commission briefing, February 23, 2020.

UCS Perspectives on Advanced Reactor Regulatory and Policy Issues, presentation at NRC Commission briefing, February 6, 2020.

Law and Innovation: Nuclear Power Development, Boston Bar Association, panel discussion, May 8, 2019.

UCS Views on the Reactor Oversight Process, presentation at the NRC Regulatory Information Conference, March 13, 2019.

6 The Nuclear Regulatory Commission after Fukushima: Lessons Learned and Unlearned, CISAC Seminar, Center for International Security and Cooperation, Stanford University, December 4, 2018.

Learning from the Hard Cases: Iran, North Korea, Japan, and the Future of Nuclear Nonproliferation, Physics Department colloquium, Duke University, November 14, 2018.

Addressing the Impacts of HEMPs/GMDs on Nuclear Power Plants, presentation at the Electromagnetic Defense Task Force Summit, Potomac, MD, August 20, 2018.

Testimony on advanced nuclear reactor and fuel cycle legislation before the House Energy and Commerce Subcommittee on Energy, May 22, 2018.

UCS Perspectives on Advanced Reactor Regulatory and Policy Issues, presentation at NRC Commission briefing, April 24, 2018.

Recycling Nuclear Waste: Risks and Benefits, Leo Szilard Lectureship Award talk, American Physical Society April Meeting, Columbus, OH, April 14, 2018.

UCS Perspectives on Accident-Tolerant Fuel, presentation at NRC Commission briefing, April 12, 2018.

Dilute and Dispose: The Best Approach for Surplus Plutonium Disposition, presentation to the National Academy of Sciences Committee on Disposal of Surplus Plutonium in the Waste Isolation Pilot Plant, Washington, DC, November 29, 2017.

Testimony on the Nuclear Waste Policy Amendment Acts of 2017 before the House Energy and Commerce Subcommittee on Environment, April 26, 2017.

Testimony on the Nuclear Energy Innovation and Modernization Act before the Senate Committee on Environment and Public Works, March 8, 2017.

The U.S. Surplus Plutonium Dilemma: Lessons for Japan, presentation at the Conference on the U.S.-Japan Nuclear Cooperation Agreement and Japans Plutonium Policy, Tokyo, Japan, February 24, 2017.

Physical Security of Nuclear Facilities in the Post-9/11 Era, Nuclear Science and Engineering Energy Seminar, Colorado School of Mines, October 2016.

Perspectives on Security Issues, presentation at NRC Commission closed briefing, June 23, 2016.

Testimony on advanced nuclear reactors before the Senate Committee on Environment and Public Works, Subcommittee on Clean Air and Nuclear Safety, April 21, 2016.

7 Alternatives to MOX, presentation to the Savannah River Site Citizens Advisory Board, Augusta, GA, March 29, 2016 (with Frank von Hippel)

NRCs Fukushima Response: Lessons Learned and Lessons Unheeded, presentation at the NRC Regulatory Information Conference, March 10, 2016.

Fixing the NRCs Broken Framework for Reducing Severe Accident Risk, presentation to the NRC Advisory Committee on Reactor Safeguards, December 1, 2015.

UCS Perspectives on NRC and Industry Actions in Response to Fukushima, presentation at NRC Commission briefing, April 30, 2015.

Perception versus Reality: UCS Views on Nuclear and Radiological Terrorism Risks, presentation at the Institute of Nuclear Materials Management Reducing the Risk Workshop, Washington, DC, March 17, 2015.

Fukushima and its Lessons for Nuclear Safety, seminar at The Library of Congress, February 19, 2015.

Production of Mo-99 Without the Use of Highly Enriched Uranium: Perspectives of the Union of Concerned Scientists, presentation to the National Academy of Sciences Committee on Status of Mo-99 Production, February 12, 2015.

Safety and Security of Spent Fuel Storage in the United States, presentation to the National Academy of Sciences Fukushima Lessons Learned Panel, January 29, 2015.

UCS Views on the NRCs Human Reliability Program Activities and Analyses, presentation at NRC Commission briefing, May 29, 2014.

Public Confidence and Force-on-Force Inspections, presentation at the NRC Regulatory Information Conference, March 13, 2014.

Fukushima: The Story of a Nuclear Disaster, lecture at the Carter Presidential Library, Atlanta, GA, February 10, 2014.

UCS Views on NTTF Recommendation 1 and the NRC Staff Proposal, presentation at NRC Commission briefing, January 10, 2014.

UCS Perspective on Expedited Transfer of Spent Fuel to Dry Casks, presentation at NRC Commission briefing, January 6, 2014.

Security Impacts of Emerging Nuclear Technologies, MITRE STEP Technical Exchange, McLean, VA, December 3, 2013.

8 UCS Perspective on Considering Economic Consequences in the NRCs Regulatory Framework, presentation at NRC Commission briefing, September 11, 2012.

Lessons from Fukushima for Improving Nuclear Safety, American Physical Society March Meeting, Boston, MA, March 1, 2012.

Lessons from Fukushima for Improving Nuclear Safety, Physics Department Colloquium, University of Central Florida, February 24, 2012.

Testimony on the Blue Ribbon Commission Report before the House Committee on Energy and Commerce, Subcommittee on Environment and the Economy, February 1, 2012.

UCS Perspective on the Prioritization of NTTF Recommendations, presentation at NRC Commission briefing, October 11, 2011.

UCS Perspective on the Japan Task Force Report Short-Term Actions, presentation at NRC Commission briefing, September 14, 2011.

Testimony on small modular reactors before the Senate Committee on Appropriations, Energy and Water Subcommittee, July 14, 2011.

Testimony on nuclear power legislation before the Senate Energy and Natural Resources Committee, June 7, 2011.

Testimony on the U.S. government response to Fukushima before the House Energy and Commerce Committee, Subcommittee on Oversight and Investigations, April 6, 2011.

Testimony on nuclear safety and Fukushima before the Senate Committee on Environment and Public Works, March 16, 2011.

UCS Perspective on Maintaining Enhanced Safety for New Reactors, presentation at NRC Commission briefing, October 14, 2010.

Limiting Future Proliferation and Security Risks, presentation to the Blue Ribbon Commission on Americas Nuclear Future, Reactor and Fuel Cycle Technology Subcommittee, October 12, 2010.

Opportunities in Reactor and Fuel Cycle Technologies, presentation to the Blue Ribbon Commission on Americas Nuclear Future, Reactor and Fuel Cycle Technology Subcommittee, August 30, 2010.

Proliferation and Terrorism Risks of the Nuclear Renaissance, New York State American Physical Society meeting, April 24, 2010.

9 Reprocessing in the U.S.: Just Say No, presentation at the NRC Fuel Cycle Information Exchange, June 25, 2009.

Nuclear Concerns: Safety, Security, Waste and Proliferation, presentation at the Nuclear Nonoperating Owners Group Conference, Baltimore, MD, April 23, 2009.

NRC Regulation of the Nuclear Fuel Cycle: Safety and Security Concerns, presentation at the NRC Regulatory Information Conference, March 11, 2009.

UCS Views on Risk-Informed Regulation, presentation at NRC Commission briefing, February 4, 2009.

Licensing Challenges for Fuel Cycle Facilities Under the Global Nuclear Energy Partnership, U.S. Nuclear Regulatory Fuel Cycle Information Exchange, Rockville, MD, June 12, 2007.

The Nuclear Renaissance and the Spread of Nuclear Weapons, American Physical Society Ohio Chapter Meeting, May 7, 2007.

Recycling Nuclear Waste, American Physical Society Annual April Meeting, Jacksonville, FL, April 15, 2007.

The Security Imperative of Eliminating Commercial Use of HEU, presentation to the Committee on Medical Isotope Production Without Highly Enriched Uranium, National Academy of Sciences, Washington, DC, February 15, 2007.

Recycling Nuclear Waste, Peace Studies Seminar, Cornell University, November 29, 2006.

Nuclear Power and Nuclear Proliferation, Citizens for Global Solutions conference, Washington, DC, November 13, 2006.

Next-Generation Nuclear Plants: Safety and Security, presented at Is Nuclear Power a Solution to Global Warming and Rising Energy Prices?, American Enterprise Institute conference, Washington, DC, October 6, 2006.

Recycling Nuclear Waste: Technical Difficulties and Proliferation Concerns, Physics Department Colloquium, Case Western Reserve University, Cleveland, OH, September 14, 2006.

The Chernobyl Source Term: Implications for Nuclear Safety, international conference Chornobyl +20: Remembrance for the Future, Kiev, Ukraine, April 23-25, 2006.

Public Health Consequences of a Severe Accident or Attack at a Nuclear Plant, Nuclear Policy Research Institute Conference on Nuclear Power and Global Warming, Airlie House, Warrenton, VA, November 7, 2005.

Testimony before the Subcommittee on Clean Air, Climate Change on Nuclear Safety, Committee

10 on Environment and Public Works, United States Senate, May 26, 2005.

Safeguarding the U.S. Plutonium Disposition Program Against Nuclear Terrorism, Science and Global Security Program seminar, Woodrow Wilson School of Public and International Affairs, Princeton University, December 9, 2004.

Status of the Security Regime for the U.S. Mixed-Oxide Fuel Program, Managing the Atom Project seminar, Belfer Center for Science and International Affairs, Kennedy School of Government, Harvard University, November 2, 2004.

"U.S. Nonproliferation Policy, Plutonium Disposition and the Threat of Nuclear Terrorism,"

seminar on "Recycling Plutonium: Risks and Alternatives," sponsored by the Green Group, European Parliament, Brussels, Belgium, January 9, 2003.

"Current Status of the U.S. Plutonium Disposition Program," seminar, Princeton University Program on Science and Global Security, Princeton University, Princeton, NJ, June 12, 2002.

"Controlling Fissile and Radioactive Material," Public Health Summit on Weapons of Mass Destruction, sponsored by Physicians for Social Responsibility and the UCLA School of Public Health, UCLA, Los Angeles, June 2, 2002.

"Assessing the U.S. Government Response to the Nuclear Terrorism Threat After 9/11,"

presentation to the Joint Atomic Energy Intelligence Committee, McLean, VA, May 9, 2002.

"Upgrading Physical Protection at Nuclear Facilities to Address New Threats," MIT Security Studies Seminar, MIT, Boston, MA, April 18, 2002.

"Perspectives on New Plant Licensing," presentation at the U.S. Nuclear Regulatory Commission Briefing on Readiness for New Plant Applications and Construction, Washington, DC, July 19, 2001.

"Regulatory Challenges for Future Nuclear Plant Licensing: A Public Interest Perspective," U.S.

NRC Advisory Committee on Reactor Safeguards (ACRS) Workshop on New Nuclear Plant Licensing, Washington, DC, June 5, 2001.

"The Future of Nuclear Power: A Public Interest Perspective," 2001 Symposium of the Northeast Chapter of Public Utility Commissioners, Mystic, CT, May 21, 2001.

Statement at the U.S. Nuclear Regulatory Commission Briefing on Office of Nuclear Regulatory Research Programs and Performance, May 11, 2001.

"Barriers to Deployment of Micro-Nuclear Technology," presentation at the workshop on "New Energy Technologies: A Policy for Micro-Nuclear Technologies," James A. Baker III Institute for Public Policy, Rice University, Houston, TX, March 19-20, 2001.

11 "Aging Research and Public Confidence," presentation at the U.S. Nuclear Regulatory Commission 2001 Regulatory Information Conference (RIC), Washington, DC, March 14, 2001.

NRC Reactor Safeguards Activities," presentation at the U.S. Nuclear Regulatory Commission 2001 Regulatory Information Conference (RIC), Washington, DC, March 14, 2001.

"DOE's Nuclear Material Stabilization Approach: The Failure of Transparency," Embedded Topical Meeting on DOE Spent Nuclear Fuel and Fissile Material Management, American Nuclear Society Annual Meeting, San Diego, CA, June 2000.

"The Status of Reactor Safeguards Initiatives," presentation at the U.S. NRC 2000 Regulatory Information Conference, Washington, DC, March 29, 2000.

"Safety Questions Concerning MOX Fuel Use in Proposed U.S. Reactors," Sixth International Policy Forum on the Management and Disposition of Nuclear Weapons Materials, sponsored by Exchange/Monitor Publications, Washington, DC, June 1999.

"Transparency and Plutonium Disposition," ISIS Workshop on Comprehensive Controls on Plutonium and Highly Enriched Uranium: Long-Term Problems and Prospects for Solutions, sponsored by the Institute for Science and International Security, Washington, DC, June 1997.

"Ship Transportation of Radioactive Materials," presentation to the Marine Board of the National Research Council, U.S. National Academy of Sciences, Woods Hole, MA, June 20, 1996.

"The Importation and Storage of High-Level Radioactive Wastes at Rokkasho-Mura: Safety Concerns," presentation at the Public Forum on High-Level Nuclear Waste and Reprocessing,"

Aomori, Japan, April 16, 1996.

"Perspectives on U.S. Options for Disposition of Excess Plutonium," Third International Policy Forum on the Management and Disposition of Nuclear Weapons Materials, sponsored by Exchange/Monitor Publications, Landsdowne, VA, March 21, 1996.

"Addressing Safety Issues in the Sea Transport of Radioactive Materials," presentation to the Special Consultative Meeting of Entities Involved in the Marine Transport of Nuclear Materials Covered by the INF Code," International Maritime Organization, London, March 4-6, 1996.

"Prospects and Unsolved Issues for Plutonium Immobilization," INESAP/IANUS/UNIDIR Fissile Cutoff Workshop, Palais des Nations, Geneva, June 1995.

"An Intermediate Solution for Plutonium from Dismantled Nuclear Warheads," Annual Meeting of the German Physical Society, Berlin, Germany, March 1995.

"The Sea Transport of High-Level Radioactive Waste: Environmental and Health Concerns,"

12 Channel Islands International Conference on Nuclear Waste, St. Helier, Jersey, United Kingdom, January 1995.

Conference Papers E. Lyman, Proliferation and Terrorism Issues Related to Noble Gas Management at Molten Salt Reactors, GLOBAL 2019 Conference, American Nuclear Society, Seattle, WA, September 2019.

E. Lyman, Update on the Decline of the NRCs Security Inspection Program, 60th Annual Meeting of the Institute of Nuclear Materials Management, Palm Desert, CA, July 2019.

E. Lyman, The Industrys War on Force-on-Force Inspections, 58th Annual Meeting of the Institute of Nuclear Materials Management, Indian Wells, CA, July 2017.

E. Lyman, External Assessment of the U.S. Sodium-Bonded Spent Fuel Treatment Program, International Conference on Fast Reactors and Related Fuel Cycles, International Atomic Energy Agency, Yekaterinburg, Russia, June 2017.

E. Lyman, Developing a Verification Regime for Direct Disposal of Excess Plutonium, Advances in Nuclear Nonproliferation Technology and Policy Conference, American Nuclear Society, Santa Fe, NM, 25-30 September 2016.

E. Lyman, Toward a Global Composite Adversary Force, 57th Annual Meeting of the Institute of Nuclear Materials Management, Atlanta, GA, July 2016.

E. Lyman, Security and Nonproliferation Assessment of Breed-and-Burn Systems, GLOBAL 2015 Conference, Paris, France, September 2015.

E. Lyman, Material Accounting Issues at the MOX Fuel Fabrication Facility, 2014 IAEA Safeguards Symposium, International Atomic Energy Agency, Vienna, Austria, October 2014.

E. Lyman, Spent Nuclear Fuel Sabotage: An Unnecessary Risk? 55th Annual Meeting of the Institute of Nuclear Materials Management, Atlanta GA, July 2014.

E. Lyman, WIPP and Plutonium Disposition: End of the Spent Fuel Standard? 54th Annual Meeting of the Institute of Nuclear Materials Management, Palm Desert, CA, July 2013.

E. Lyman, MC&A Issues at the MOX Fuel Fabrication Facility, 53th Annual Meeting of the Institute of Nuclear Materials Management, Orlando, FL, July 2012.

E. Lyman, A Comprehensive Approach to Protecting Nuclear Facilities and Materials from Terrorist Threats, 2012 Seoul Nuclear Security Symposium, Seoul, Republic of Korea, March

13 2012.

E. Lyman, Is Dilution the Solution to the Plutonium Threat? 52th Annual Meeting of the Institute of Nuclear Materials Management, Palm Desert, CA, July 2011.

E. Lyman, Resolving a Safeguards Paradox, 2010 IAEA Safeguards Symposium, International Atomic Energy Agency, Vienna, Austria, November 2010.

E. Lyman, NRC: Taking Spent Fuel Security in the Wrong Direction, 51th Annual Meeting of the Institute of Nuclear Materials Management, Baltimore, MD, July 2010.

E. Lyman, Severe Accident Consequence Assessment Regulatory Guidance: A Critique, American Nuclear Society Annual Meeting, San Diego, CA, June 2010.

E. Lyman, Promoting Mediocrity: NRCs Policy for New Facility Security Design, 50th Annual Meeting of the Institute of Nuclear Materials Management, Tucson, AZ, July 2009.

E. Lyman, Excess Plutonium Disposition: Requiem for a Dream, 49th Annual Meeting of the Institute of Nuclear Materials Management, Nashville, TN, July 2008.

E. Lyman, Revising the Rules for Material Protection, Control and Accounting, 8th International Conference on Facility Operations - Safeguards Interface, Portland, OR, March 30 - April 4, 2008.

E. Lyman, Regulatory Challenges Facing the Global Nuclear Energy Partnership, GLOBAL 2007 Conference, Boise, ID, September 2007.

E. Lyman, Envisioning a World Without Uranium Enrichment, 48th Annual Meeting of the Institute of Nuclear Materials Management, Tucson, AZ, July 2007.

E. Lyman, The Global Nuclear Energy Partnership: Will it Advance Nonproliferation or Undermine it? 47th Annual Meeting of the Institute of Nuclear Materials Management, Nashville, TN, July 2006.

E. Lyman, Can Nuclear Fuel Production in Iran and Elsewhere Be Protected Against Diversion?

paper presented at the Nonproliferation Policy Education Center/Kings College-London Conference After Iran: Safeguarding Peaceful Nuclear Energy, London, October 2-3, 2005.

E. Lyman, The Erosion of Physical Protection Standards Under the MOX Fuel Program, 46th Annual Meeting of the Institute of Nuclear Materials Management, Phoenix, AZ, July 2005.

E. Lyman, Extending the Foreign Spent Fuel Acceptance Program: Policy and Implementation Issues, 26th International Meeting on Reduced Enrichment for Research and Test Reactors, IAEA, Vienna, Austria, November 2004.

14 E. Lyman, Using Bilateral Mechanisms to Strengthen Physical Protection Worldwide, 45th Annual Meeting of the Institute of Nuclear Materials Management, Orlando, FL, July 2004.

E. Lyman, The Congressional Attack on RERTR, 25th International Meeting on Reduced Enrichment for Research and Test Reactors, RERTR-2003, Chicago, IL, October 2003.

E. Lyman, Nuclear Plant Protection and the Homeland Security Mandate, 44th Annual Meeting of the Institute of Nuclear Materials Management, Phoenix, AZ, July 2003.

E. Lyman and A. Kuperman, "A Reevaluation of Physical Protection Standards for Irradiated HEU Fuel," 24th International Meeting on Reduced Enrichment for Research and Test Reactors, RERTR-2002, Bariloche, Argentina, November 2002.

E. Lyman, "Material Protection, Control and Accounting at the U.S. MOX Fuel Fabrication Plant:

Merely an Afterthought?" 43rd Annual Meeting of the Institute of Nuclear Materials Management (INMM), Orlando, FL, June 2002.

E. Lyman, "Terrorism Threat and Nuclear Power: Recent Developments and Lessons to be Learned," Symposium on Rethinking Nuclear Energy and Democracy after 9/11, sponsored by PSR/IPPNW Switzerland, Basel, Switzerland, April 2002.

E. Lyman, remarks for Expert Panel on Advanced Reactors, Nuclear Safety Research Conference, U.S. Nuclear Regulatory Commission, Washington, DC, October 2001.

E. Lyman, "The Future of Immobilization Under the U.S.-Russian Plutonium Disposition Agreement," 42nd Annual Meeting of the Institute of Nuclear Materials Management (INMM),

Indian Wells, CA, July 18, 2001.

E. Lyman, comments in the Report of the Expert Panel on the Role and Direction of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, May 2001.

E. Lyman, "Can the Proliferation Risks of Nuclear Power be Made Acceptable?" Nuclear Control Institute 20th Anniversary Conference, Washington, DC, April 9, 2001.

E. Lyman and P. Leventhal, "Radiological Sabotage at Nuclear Power Plants: A Moving Target Set," 41st Annual Meeting of the INMM, New Orleans, LA, July 2000.

E. Lyman, "Comments on the Storage Criteria for the Storage and Disposal of Immobilized Plutonium," Proceedings of the Institute for Science and International Security Conference on "Civil Separated Plutonium Stocks --- Planning for the Future," March 14-15, 2000, Washington, DC, Isis Press, 135.

E. Lyman, "The Sea Shipment of Radioactive Materials: Safety and Environmental Concerns,"

15 Conference on Ultrahazardous Radioactive Cargo by Sea: Implications and Responses, sponsored by the Maritime Institute of Malaysia, Kuala Lumpur, Malaysia, October 1999.

E. Lyman, "A Critique of Physical Protection Standards for Irradiated Materials," 40th Annual Meeting of the INMM, Phoenix, AZ, July 1999.

E. Lyman, "DOE Reprocessing Policy and the Irreversibility of Plutonium Disposition,"

Proceedings of the 3rd Topical Meeting on DOE Spent Nuclear Fuel and Fissile Materials Management, American Nuclear Society, Charleston, SC, September 8-11, 1998, 149.

E. Lyman, "Japan's Plutonium Fuel Production Facility (PFPF): A Case Study of the Challenges of Nuclear Materials Management," 39th Annual Meeting of the INMM, Naples, FL, July 1998.

E. Lyman, "Safety Aspects of Unirradiated MOX Fuel Transport," Annex 2b of the Comprehensive Social Impact Assessment of MOX Use in Light Water Reactors, Citizens' Nuclear Information Center, Tokyo, November 1997.

E. Lyman, "Unresolved Safety Issues in the Storage and Transport of Vitrified High-Level Nuclear Waste," 38th Annual Meeting of the INMM, Phoenix, AZ, July 1997.

E. Lyman, "A Perspective on the Proliferation Risks of Plutonium Mines," proceedings of the Plutonium Stabilization and Immobilization Workshop, U.S. Department of Energy, Washington, DC, December 12-14, 1995, CONF-951259, p, 445.

E. Lyman, "Assessing the Proliferation and Environmental Risks of Partitioning-Transmutation,"

Fifth International Summer Symposium on Science and World Affairs, Cambridge, MA, USA, July 1993.

Letters to the Editor and Op-Eds R. L. Garwin, E. S. Lyman, F. N. von Hippel, A New Nuclear Threat. The New York Times, June 18, 2024.

E. Lyman, Conflicts of Interest Surrounding Nuclear Laws Could Undermine U.S. Safety, The Hill, February 28, 2024.

E. Lyman, The Misguided Push to Weaken Nuclear Safety Standards is Gaining Steam, The Hill, July 25, 2023.

E. Lyman, Trump Should Stick to His Guns and Close Failed South Carolina Nuclear MOX Project, The Hill, October 20, 2018.

A. Kuperman and E. Lyman, Why is NASA Testing Bomb-Grade Materials for its Mars Mission? Baltimore Sun, August 20, 2017.

16 E. Lyman, Hanford Mishap Should Be Wake-Up Call, The Hill, May 16, 2017.

E. Lyman, Nuclear Cybersecurity: Why We Should Worry, New York Times, January 26, 2016.

E. Lyman and F. von Hippel, Direct Disposal is a Better Solution for South Carolinas Plutonium Problem (op-ed), Augusta Chronicle, October 24, 2015.

E. Lyman, The Value of a Life, New York Times, February 23, 2011.

E. Lyman, The Downside of Nuclear Energy, Washington Post, April 21, 2006.

E. Lyman, Reprocessing Nuclear Waste: Forget It, Topeka Capital-Journal, December 24, 2005.

E. Lyman, The Wrong Way to Get Cheap Electricity, Chicago Sun-Times, December 16, 2005.

E. Lyman, Uranium on Campus, New York Times, August 23, 2004 L. Gronlund and E. Lyman, Halting the Spread of Nuclear Arms, New York Times, December 28, 2003.

E. Lyman, "Troubles at Indian Point," New York Times, January 25, 2003.

E. Lyman and P. Leventhal, "Nonessential Nukes" (op-ed), Washington Post, November 26, 2002.

P. Leventhal and E. Lyman, "Shipping Plutonium," New York Times, July 12, 2002.

E. Lyman, "Indian Point Reactor," New York Times, January 27, 2002.

E. Lyman, "Spent Nuclear Fuel," New York Times, June 3, 2001.

E. Lyman and P. Leventhal, "Better Plutonium Plan," New York Times, February 5, 1998.

E. Lyman, "A Safer Plutonium Plan," Washington Post, August 24, 1997.

P. Leventhal and E. Lyman, "Who Says Iraq Isn't Making a Bomb?" International Herald Tribune, November 2, 1995.

H. Feiveson and E. Lyman, "No Solution to the Plutonium Problem," Washington Post, July 29, 1994.

E. Lyman, "Getting Rid of Weapon Plutonium," Bulletin of the Atomic Scientists, July/August 1994.