Between February and September, 2006, HOME contracted with the Southern Inyo Fire Protection District (SIFPD) to provide an in depth assessment of Hazardous Materials Transportation through their district on CA Routes 127 and 178. Both roads are classified as Minor Arterial rural highways, and sustain a wide variety of types of traffic. In addition to being the southern access route to Death Valley National Park and the Owens Valley and Eastern Sierras beyond, CA Route 127 is a shortcut from southern California to NV Highway 95, which stretches between Las Vegas and Reno, and to western and central Nevada. CA Route 127 is also a primary corridor for transporting low-level and transuranic radioactive waste to and from the Nevada Test Site, and for hazardous waste in route to the US Ecology Nevada facility in Beatty, NV. It is also used by hard-rock mines, mills, alfalfa ranches and the Amargosa Valley and Pahrump dairies to haul a wide range of commodities south to Interstate 15.
The area is subject to extreme weather conditions. The Amargosa River, usually dry on the ground surface but subject to sudden flash floods, crosses back and forth under Route 127 thirteen times between Highway 95 and Baker, California, flooding the roadway about twice a year, and causing severe damage every two years on average, according to one Caltrans District 9 report.
The survey provided 175 hours of direct traffic data collection. In addition, the study reviews and compares existing data collected by Caltrans, California Highway Patrol, the Inyo County Yucca Mt. Oversight Office, and the Inyo County Sheriff's Dept.
Key findings about Hazardous Materials Transportation:
1. Hazardous materials placards were observed for every class except radioactive.
2. 78% of all placarded vehicles traveled exclusively on SR 127, 73% north and 5% south. 15% of these trucks carried fuels and 85% carried hazardous waste.
3. Only 22% of placarded trucks also traveled to or from Pahrump on SR 178 from the Shoshone intersection of SR 127 and SR 178. These carried fuels, carbon dioxide and fireworks.
4. Hazardous waste for disposal at US Ecology Nevada comprised 65% of all hazardous placards documented. No radiological materials to the Nevada Test Site were observed, although DOE reports 46 radiological shipments on SR 127 Jan.-Sept. 06.
5. For every placarded hazardous truck, at least 3 unplacarded hazardous waste trucks were identified by trailer type, convoy configuration or carrier name. We must assume that any material that is required by law to be transported for disposal to US Ecology Nevada is hazardous by definition. Together, all identified hazardous materials comprised 30% of total truck traffic observed.
6. Placards used for liquid or solid for hazardous wastes were generally very broad, and some also indicated that smaller quantities of multiple materials were being shipped on the same vehicle. This could present more complex problems in case of a traffic accident.
7. EPA documents filed annually by US Ecology Nevada indicate the handling of very hazardous chemicals, such as Aldrin and Chlordane, various Benzene compounds and much more. These substances can cause a very wide range of health problems if released to the biosphere.
8. Although we observed no placarded radioactive shipments to the Nevada Test Site, the Dept. of Energy reports 46 on SR 127 between January 1 and September 30, 2006.
We suggest the following steps for the SIFPD to pursue to further evaluate risks within the district:
1. A total of thirteen different response protocols, as detailed in the 2004 Emergency Response Guide, are recommended for the placards recorded in the survey. Further study of these response protocols may be helpful in evaluating SIFPD response capacity for potential hazardous material accidents in the future.
2. The chemical content of all US Ecology wastes are on record with the EPA and available on the Internet at several websites, with varying degrees of analysis already provided. Any of them could be on roads within the district at any time, in mixed loads. We believe that the hazardous wastes of greatest concern are the liquids being transported to US Ecology Nevada and radiological materials to the Nevada Test Site. We recommend further evaluation of all the more dangerous chemicals transported for disposal, to determine what protocols, equipment and training would be required to handle potential accidents.
3. Finally, based on the unusually high levels of hazardous materials transportation in the district as confirmed in this study, we recommend a future needs assessment by the SIFPD, including complete equipment and skills inventories as well as a long-term multi-agency emergency preparedness plan. We hope that sufficient funding could be secured for this assessment, and to secure the recommended equipment and training when the assessment is complete.
4. It should also be noted that studies done this year by a range of research firms on behalf of the Inyo County Yucca Mt. Oversight Office state clearly that SR 127 is the likeliest transportation route for thousands of shipments of high-level radioactive waste to Yucca Mt., should the proposed repository become licensed. Improvements to the road bed recommended in these reports, as well as additional training and equipment for the SIFPD, would take many years to put in place. The Task V report (available on the Inyo County Yucca Mt. Oversight Office website) specifically recommends some precedents and possible avenues for securing DOE funding for these purposes. We recommend follow-up with the appropriate agencies now and in future years.