To learn more about the fight against the Yucca dump, check out the following websites:
http://www.nirs.org/radwaste/yucca/yuccahome.htm
http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_power_plants/nukewaste/yucca/
http://www.state.nv.us/nucwaste/
Nevada Nuclear Waste Task Force, Citizen Alert
Public Citizen, Nuclear Information and Resource Service
Blue Ridge Environmental Defense League, Healing Ourselves & Mother Earth
August 14, 2006
Dr. Jane Summerson
EA Document Manager
U.S. Department of Energy
1551 Hillshire Drive
Las Vegas, NV 89134-6321
Re: Draft Environmental Assessment for the Proposed Infrastructure Improvements for the Yucca Mountain Project, Nevada (DOE EA 1566)
In this Draft Environmental Assessment (EA) the Department of Energy (DOE) describes its need for infrastructure improvements at the Yucca Mountain site that would be a stopgap measure until a construction authorization decision is made by the Nuclear Regulatory Commission (NRC). The time period is assumed to be up to ten years. The estimated time to complete the preferred, proposed option in this EA is two years which, under the latest Yucca Mountain Repository Schedule, could disrupt or conflict with Nevada rail construction that is scheduled to begin in October 2009. The completion of the proposed, preferred action would occur approximately two years before DOE’s estimate of the granting of a construction authorization by the NRC. At that time DOE expects to begin multiple and aggressive building projects at Yucca Mountain and would most likely have drastic changes in infrastructure needs. The cost of the proposed improvements is not shown in the EA but would no doubt be large. After carefully considering the descriptions and analyses of the proposed actions, we believe that the preferred option is unwarranted and the clear and proper choice is the no-action alternative.
The EA describes the need to repair, replace or improve facilities, structures, roads and utilities so as to enhance safety, continue ongoing operations, scientific testing, and routine maintenance to support scientific activities and testing.
In Section 2.2 Proposed Action, it is stated in 2.2.2.1 that “existing distribution equipment (poles and cable) would not be removed and might be maintained as a backup power supply for the Yucca Mountain.” If the power system is good enough for repository backup, it certainly is good enough for the duration of the time period until there is a decision about whether or not there will be a repository.
Section 2.2.3 describes the need for a Central Operations Area (approximately one-half mile southwest of the North Portal) however, on the map, this facility is shown to be southeast of the North Portal. Likewise, in Section 2.2.4, part of the proposed action would include “repair to the equipment-storage pad approximately one-mile northeast of the North Portal.” On the map, the pad is west of the portal. At a time when the repository design has yet to be determined, it is not sensible to construct six large support buildings (Sec. 2.2.3) to replace “temporary” structures. Until a licensing decision is made by the NRC, the Yucca Mountain Project is a temporary operation.
The most extravagant part of the preferred option is the building of a highway to the top of, and along the crest of, Yucca Mountain. Any access required by scientists, engineers, or craft personnel can continue to be done utilizing the existing road, with periodic maintenance. The proposed improvements (Sec. 2.2.1.1) call for removing enough of the crest to build a roadbed sixty feet wide which, certainly during construction, would rule out scientific activity and would only serve the YMP tourist program. This construction would occur at a time when it could disrupt or prevent the scientific testing and activities for confirmation which the EA states would be the ongoing operations at the site. In addition, the building of a new road over Fortymile Wash, with culverts for flood water, could alter the hydrology and nullify the results of the previous studies of the infiltration in that area
The EA , in its discussion of vegetation (Sec. 3.3), explains that different species of vegetation grow above 4,000 feet in the Yucca Mountain region. This vegetation is important to the culture, and is a significant element, of what is a sacred area for Native Americans. The proposed action would destroy 253 acres of desert tortoise habitat (Sec. 4.4.2), significantly increase the use of water during the 2 year period (Sec. 4.5.2), and would impact cultural resources which cannot be replaced or reclaimed (Sec.4.7.2). The EA is wrong when it states in Table 1.1 that there are no impacts to Environmental Justice. Environmental Justice is a part of the American Indian Concerns and for the tribes and Nations involved. The EA states: “The American Indian view includes little or no differentiation between types of impacts (direct versus indirect), but considers all impacts to be adverse and immune to mitigation.” ( Sec. 4.8.1). These impacts attack the core of the culture of the native populations and cannot be mitigated by “...continue(ing) to interact with tribes and organizations through the Department’s Native American Interaction Program.” These are not matters that can be talked away.
According to the Draft, the need for the proposed, preferred option is to enhance safety, continue ongoing operations, scientific activities and testing for confirmation. The EA states that these tasks are currently being carried out by a maximum of between 250 and 350 scientists, engineers and craft personnel for routine operations (Sec. 3.9). That number would not be expected to increase unless and until a construction authorization is issued by the NRC. The proposed improvements would be excessive and unwarranted to serve a workforce of that size.
If the muck-pile rock material is crushed and used for fill as proposed, cristobalite dust can become airborne (Sec. 4.12.2). Rather than enhancing the safety of the workers, exposure to dust from material in the muck pile – containing significant amounts of hazardous and carcinogenic crystalline silica, will present unsafe conditions as it did during tunneling operations inside the exploratory studies facility.
It is unrealistic to propose that construction associated with the improvement project would be curtailed from March 15 through July 30 to avoid migratory bird-nesting (Table 4-1). This is the optimal outdoor construction time in the desert southwest and we would not trust DOE to sacrifice milestones, schedules and deadlines for nesting birds.
Section 4.16.1.4 states: “In general, however, current and future developments at the Nevada Test and Training Range would have negligible cumulative impacts with the proposed actions examined in this EA because these actions would not occur on the U.S. Air Force land that is used by the Department for operations at Yucca Mountain.” If this means that the actions proposed in this EA will not occur on Air Force land, the section is wrong or misleading because according to the map (Figure 2-1) the preferred option requires some of the most disruptive road construction on NV Test and Training Range land, which is also Air Force land.
According to Table 2-1 the proposed, preferred action requires the disturbance of 253 acres of land that is either designated for the Nevada Test Site, the Nevada Test and Training Range or the Bureau of Land Management for public use. In addition, Table 4-1 indicates that there could be further restrictions on public use of public land. The impact area in this EA is within the treaty lands of the Western Shoshone Nation and sacred to other Tribes and Nations. Section 3.7 states: “Years of research at and near Yucca Mountain have discovered more than 900 archaeological and historic sites. These sites range from single artifacts to campsites and quarries. Collectively, they indicate that the Yucca Mountain region has been occupied by American Indian populations for at least 12,000 years.” To simply dismiss those findings and proceed to disturb and destroy 253 additional acres of this unique area is unreasonable. To propose an action with a ten-year or less use time, for a few hundred people, to perform minimal duties while waiting out part of the NRC licensing process, is inappropriate and wasteful.
Certainly there has already been significant disruption and restrictions at the site but this EA proposes even more disturbance, much of which would be permanent or difficult and very costly to reclaim. DOE has not yet submitted a license application so there should be no expectation that the NRC will grant a construction authorization. At this time DOE should know that all facilities at Yucca Mountain are temporary and subject to removal. The no-action alternative can provide worker safety and allow for activities necessary for preparation of a license application. It is the only sensible option.
Submitted by:
Judy Treichel
Executive Director
Nevada Nuclear Waste Task Force
P. O. Box 26177
Las Vegas, NV 89126
702-248-1127
Peggy Maze Johnson
Executive Director
Citizen Alert
P. O. Box 17173
Las Vegas, NV 89114
702-796-5662
Michele Boyd
Legislative Director for Energy Programs
Public Citizen
215 Pennsylvania Ave. S. E.
Washington, DC 20003
202-454-5134
Kevin Kamps
Nuclear Waste Specialist
Nuclear Information Resource Service
6930 Carroll Avenue, Suite 340
Takoma Park, DC 20912
301-270-6477 extension 14
Janet Zeller
Executive Director
Blue Ridge Environmental Defense League
P. O. Box 88
Glendale Springs, NC 28629
336-982-2691
Jennifer Viereck
Executive Director
Healing Ourselves & Mother Earth
P. O. Box 420
Tecopa, CA 92389
760-852-4151