As public citizens, we need to be very cautious about DOE assurances concerning potential accident statistics, health risks along transportation routes and at the final depository site. We want the Yucca Mountain EIS to contain clear, realistic and honest statistics and information on these issues. The DOE has a very poor track record so far. All previous nuclear weapons and reactor sites were deemed ‘safe’ before construction and operation. However, I live near the Nevada Nuclear Test Site (NTS), and between four and ten trucks a week are rolling in to dump so-called low-level waste to mitigate clean-up problems at other DOE facilities that we were assured at the time would never happen.
I have personally followed those convoys on public roads between Tonapah and Beatty going from 95-100 miles per hour. I could not keep up with them, in the dark, on small roads over mountain passes. Errors and accidents do occur. Trucks from Fernald, Ohio, which pass over the Hoover Dam were found leaking in a public parking lot. Trucks from Lawrence Livermore Laboratories in California were turned back by the Highway Patrol because the driver could not identify what was in them. In a road blockade in 1997, a waste truck found stopped in traffic gave a reading of 179 radioactive units at a seam in the trailer. The driver had no monitoring equipment, protective clothing or gear, and who knows where he stopped for gas or meals along the way. As a private hauler, his next stop after NTS was in southern California to pick up a load of cantaloupe in that same truck.
A truck passing over a bridge in Chicago several years ago emitted a radioactive spill. Rescue Response teams were not prepared to deal with the problem and hosed the spill off the bridge and into the river. There are a whole lot of people downstream from Chicago. These are just a few incidents that I know of personally, but present enormous hazards to the public and environment.
This plan sets in motion the greatest potential threat to the health and safety of Americans in the history of the nation. Over 50 million people live within one half mile of proposed transportation routes to Yucca Mountain. Throughout 43 states, 109 cities with populations over 100,000 and thousands of smaller communities will be affected every day, let alone at times of unavoidable accidents and delays. Who can predict where these trucks will have a flat tire or other breakdown and will sit steadily emitting deadly radiation while repairs are made? An accident simple or severe could occur at any point along the millions of miles of proposed shipment pathways. And yet, there is only a handful of poorly publicized hearings in which concerned citizens, Emergency Response personnel and local government and tribal officials can ask questions and voice their concerns.
Every single community needs the opportunity to be fully informed about all potential impacts of this plan, needs the opportunity to evaluate the impacts, both physical and socioeconomic, and community requirements to address them, and needs the opportunity to voice those concerns to the DOE.
The Environmental Impact Statement should use terminology that is not highly misleading to the public. The term ‘spent fuel’ gives the impression that it is used up, less dangerous. In fact, fuel that is removed from nuclear reactors after use is ONE MILLION TIMES more radioactive than it was before. The average citizen uses this term in balancing the family checkbook. When the family budget is spent the checkbook balance is zero, not one million dollars. The appropriate term to be used is ‘irradiated’ nuclear fuel.
State laws in Nevada make it a crime to transport high-level nuclear waste across state borders. Laws also list as a felony pollution of ground water with a variety of toxic substances, including radioactivity. The Draft EIS makes it clear that it is a fact that waters would be polluted by this project. The only question is how long that would take. As citizens of Nevada we must oppose any project which flagrantly violates our right to protect our environmental resources and the lives and futures of our future generations. It is my belief that any and all persons knowingly attempting to move this project forward will be personally liable for criminal prosecution when radioactive contamination inevitably occurs.
Although beyond the purview of an EIS, it must be noted that this project sets the will of the state of Nevada and its citizens on a collision course with dictatorial federal policy. This will only lead to lengthy litigation and conflict far into the future if the project continues to attempt to move forward.
The 230 square miles proposed for withdrawal for this project lie within Western Shoshone Treaty Lands, sovereign territory under Constitutional and International Law. This treaty has already been upheld by the Organization of American States. Litigation will continue in the future in federal and international courts over already existing trespass disputes. No lands should be used for this project, including the current research phase, without explicit Western Shoshone approval.
The reason that we have been given from the beginning of this proposed project for facing the dangers of transporting such deadly materials through communities all over the nation is that such materials will ultimately be safer COMPLETELY AND PERMANENTLY ISOLATED from the biosphere within Yucca Mountain. This DEIS makes it very clear that it is not even remotely possible to isolate this material within Yucca Mountain. The planned man-made barriers, now that the DOE has finally acknowledged the impossibility of containment within existing natural barriers, will only slow down radioactive contamination for a very short time, given the deadly lifespan of this material.
Therefore, I ask you, why are we even discussing this insane idea? Your DEIS makes it clear that the goals of the project as initially stated are impossible. The final EIS must prove beyond a doubt that this material can be completely isolated or the plan should be dropped and such wasted funds should be better spent containing the materials on site until successful technologies can be fully researched and proven fail-safe.
Transportation casks in a brand new and perfect state will emit deadly radiation at dangerous levels under the best of circumstances. We are told that casks that could contain all radiation would be too heavy to move. Well, the obvious solution until this problem is solved is: DON’T MOVE THEM. We do not want rolling radiation emitters on our public highways, getting flat tires next to our schools and hospitals, rolling day after day past our homes, fields of produce and ranches that feed the nation. The cumulative effects of this constant flow of radioactive vehicles is not adequately addressed at all in this document. This is unacceptable.
When addressing a problem, especially one of this magnitude, the entire problem must be addressed, not just a part of it. The DIES talks about 100 years and 10,000 years, but this only addresses a portion of the problem, the half-life of these elements. The proposal as stated involves sticking this deadly material in the ground, covering it over and making it inaccessible when things do go wrong, and just walking away from it. There is one radioactive element mentioned in the DEIS, Neptunium, which does not even peak in its radioactive releases for 300,000 years.
As a mother, I have tried to instill, as I’m sure we all have, responsibility in our children to clean up their mess, and to consider that responsibility carefully when making a mess in the first place. We do not ask our children to do half of the dishes or to clean half of their room. Did all the motherless children get jobs with the DOE?
This document is useless unless it addresses the entire radioactivity caused by the project, 500,000 years. Who is supposed to deal with the rest of it—mutants who may be around the Las Vegas Valley in 10,000 years?
There are several plans put forth in the DIES for the design of this facility. The summary only shows a single block of storage drifts in multiple diagrams. However, in the document itself, plans are suggested for up to eight blocks within the mountain. This is very misleading. If the DOE is not sure of the final design yet, then this discussion is premature. We cannot be expected to analyze a proposal that in incomplete at this time.
The same is true of proposed transportation routes and railways that have yet to be built. It is premature to expect public evaluation when the DOE has yet to make up its own mind. The final EIS must contain clear and complete plans for all aspects of this project. Any additional developments that are not explicitly addressed in the EIS such as rail route construction must go through the entire review process at whatever point in the future they are fully developed and presented.
The important issue at stake, and the focus of the National Environmental Protection Act, is the survival of life on this planet, not expedience for nuclear utilities and governmental departments.
In the third most seismically active place on the North American Continent, The issues of earthquakes and land drift are extremely important. They are glossed over in this DEIS. There are 32 fault lines within Yucca Mt. This DEIS shows tunnels drilled through them, next to them, and with fault lines ending within tunnel structures. The Earth tried to make an obvious point in June of 1992 when over 1.25 million dollars of damage was sustained to the building for the project research at Yucca Mt. Since then hundreds of earthquakes of significant magnitude have occurred in the immediate area. The final EIS must adequately address this important concern.
Recent satellite research indicates that the earth is moving apart in the Yucca Mt. region at the rate of six inches every hundred years, or 50 feet over the 10,000 year lifespan of this project. A whole lot of casks could fall into a 50 foot chasm, or even serious shift and risk breaching with six inches of motion. This DEIS does not adequately address these concerns at all.
Population projections for health risks and socioeconomic impacts from this project do not go past the year 2001, eight years before the project is even slated to open. In fact, projections are actually below the current figures for Pahrump, the nearest large community. Las Vegas and Pahrump are the fastest growing communities in the U.S. at this time, with 5,000 per month and 1,000 per month increases respectively. The EIS must use realistic figures to project land and water use and proximity to radioactive dangers.
The Yucca Mountain site for this project was chosen in part for the desert conditions and low average rainfall in the region. However, the DIES fails to address the fact that often that entire rainfall occurs in a very few severe storms with flash flood conditions. The addition of ‘raincoats’ or drip shields to the casks does not sound like an adequate solution. The final EIS must address the many inches of rain that can occur in this region in a single hour.
Over 1,000 nuclear bombs have been detonated at the Nevada Test Site, above, below and directly within existing water sources. The cumulative effect of NTS radiation contamination in conjunction with Yucca Mountain contamination on the regional aquifers is not addressed in the DEIS at all. Use of potentially contaminated waters to form concrete barriers is not addressed at all. Excessive pumping of aquifers and how this might affect water flow of contaminate waters to surrounding communities and ranches and farms is not addressed. This must be rectified completely within the final document.
The Yucca Mt. site is supposed to be able to contain up to 70,000 tons of High-level nuclear waste upon completion (although I still can’t figure out from this DEIS which of the proposed designs that is). However, by the time the Repository is scheduled to open in 2010, there will already be enough materials ready for transport from commercial reactors to fill it completely. In addition, the site is supposed to house Navy reactor fuel, irradiated fuel from overseas reactors and other military waste.
Over the 30 year time period it is supposed to take to transport all this material to Yucca Mountain, additional irradiated fuel will be stacking up with no place to go. This plan is not going to remove the problem to one single site for careful monitoring. It is only going to contaminate irreparably a NEW site in the area of the fastest growing population in the United States while the existing sites continue on as before.
For all the reasons stated above and many more, this is a highly flawed plan that will not solve the irradiated fuel storage problem, on either a temporary or permanent basis. What the people of this nation need to hear from the DOE is a realistic and cost effective plan for:
What we do not want is the continued spending of our tax dollars to push clearly flawed proposals down our throats and into our mountains and waters, to sabotage our existing Environmental laws and State’s rights, and to further our nation’s sordid history of stealing Native lands for federal purposes.