Transportation of spent nuclear fuel (SNF) and high-level radioactive waste (HLW) is inherently risky business. At previous hearings, our preliminary transportation comments have addressed specific deficiencies in DOE's Draft Environmental Impact Statement (DEIS) regarding the radiological hazards of the SNF and HLW that DOE proposes to ship to Yucca Mountain, the shipment modes and routes, the risks associated with legal weight truck (LWT) transport, the vulnerability of shipments to human initiated events including terrorism and sabotage, DOE's failure to identify a preferred rail access corridor to Yucca Mountain, and DOE's failure to demonstrate the feasibility of heavy haul truck (HHT) transportation from an intermodal transfer station to the proposed repository, impacts of rail construction and operation, impacts on Native American lands and cultural resources, and social and economic impacts of public perception of transportation risks. These statements are available on the web at www.state.nv.us/nucwaste. At upcoming hearings we will address radiological health effects of routine transportation and radiological consequences of severe accidents.

    Today our comments focus on DOE's failure to identify the cross-country truck and rail routes evaluated in the DEIS. The draft EIS fails to identify the specific transportation routes for spent fuel and HLW shipments from specific reactor and generator locations to Yucca Mountain despite the fact that these routes were identified as part of the analyses contained in the transportation appendix. DOE, in effect, has chosen to hide these routes and simply report the analyses in a generic fashion.

    The manner in which the comment period and public hearings were noticed by DOE was and is misleading and intended to suppress public participation and public comments. Notices make no reference to the specific transportation routes, the types and volumes of shipments along each route, and the impacts to specific communities along identified routes.

    Under the DEIS mostly truck scenario, DOE's preferred Nevada route to Yucca Mountain is I-15, the Las Vegas Beltway (I-215), and US 95. Using the HIGHWAY model, DOE contractors generated national routes from the 77 shipping sites to connect with the Las Vegas Beltway. These national routes are not revealed in the DEIS, but they are disclosed in the DEIS references, which can be accessed on the worldwide web at www.ymp.gov/timeline/eis/trw1999udata.

    The routes used for the mostly truck impact analysis in the DEIS correspond to actual cross-country routes to I-15 and the Las Vegas Beltway. These routes generally are I-80 for shipments from the Northeastern and North Central states, I-70 for shipments from Southeastern and Midwestern states, and I-10 and I-40 for shipments from South Central and Southwestern states. Shipments from the Pacific Northwest and Idaho use I-84 and I-15. Shipments from Arizona and California use I-5, I-10, and I-15. [See DEIS reference TRW 1999udata, Chapter 4, file bt_map.prn. The origin-destination distances generated in miles in this file correspond to the origin-destination distances given in kilometers in DEIS Table J-11] The DEIS compares the transportation impacts calculated for the preferred route with impacts for six potential alternative routes identified by the State of Nevada to minimize shipments through the Las Vegas Valley. [See Table J-48]

    The routes used in the DEIS make Nebraska one of the most heavily affected corridor states for truck shipments to Yucca Mountain, but the DEIS makes no specific reference to transportation impacts in Nebraska. One of the major truck routes to Yucca Mountain enters Nebraska on I-680 from Iowa, reconnects with I-80 in Omaha, and follows I-80 across Nebraska and then through Wyoming and Utah. According to the HIGHWAY model outputs in the DEIS reference, trucks using this route travel 459 miles in Nebraska in about 7 hours. Truck shipments using this route are presented in Table 1. Under the mostly truck scenario, proposed action, more than 20,400 truck shipments of SNF and HLW (about 41% of the total) traverse Nebraska over 24 years. Under the mostly truck scenario, modules 1 & 2, about 33,700 truckloads of SNF and HLW (about 35% of the total) traverse Nebraska over 39 years. Under either scenario, an average of two trucks per day would travel through Nebraska every day for decades. Additionally, Nebraska would be traversed by about 1,000 truck shipments of greater-than-Class-C low-level radioactive wastes to Yucca Mountain during the same time period.

    Rail shipments to Yucca Mountain would have an even heavier impact on Nebraska. The DEIS evaluated four rail routing scenarios generated using the INTERLINE model. Under the DEIS routing scenarios, two major streams of rail shipments to Yucca Mountain converge in Gibbon, Nebraska, at the junction of the Union Pacific mainlines from Chicago and Kansas City. A smaller number of shipments travel the UP from Nebraska City through Omaha to Fremont, and the BNSF from Pacific Junction, Iowa through Lincoln to Denver. Rail shipments along these routes, which total more than 900 route miles in Nebraska, are presented in Tables 2 and 3. Under the mostly rail scenario, proposed action, more than 8,900 rail shipments (about 82% of the total) traverse Nebraska over 24 years. Under the mostly rail scenario, modules 1 & 2, more than 13,900 rail shipments (about 70% of the total) traverse Nebraska over 39 years. Under either scenario, an average of 1 rail cask-shipment per day would travel through Nebraska every day for decades. Additionally, I-680 and I-80 through Nebraska would be traversed by about 1,900 to 2,600 truck shipments of SNF from reactors in New England, New York, and Minnesota, an average of about one truck shipment per week, during the same time period.