San Bernardino, California, is an especially appropriate location for a public hearing on DOE's Yucca Mountain draft EIS. California will be heavily impacted by the transportation of spent nuclear fuel (SNF) and high-level radioactive waste (HLW) to the proposed repository. San Bernardino will likely be one of the most heavily affected cities in California. Under some scenarios evaluated by DOE, all of the shipments to Yucca Mountain would pass through San Bernardino County.

The DEIS fails to identify the specific transportation routes through California evaluated by DOE contractors as part of the analyses reported in Chapter 6 and Appendix J. 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. In January, DOE decided to reveal state route maps on its website at http://www.ymp.gov/timeline/eis/routes/ca_b_r00.pdf. Attachment 1 shows DOE's California map. DOE has not, however, provided information on the projected types and numbers of shipments along each route. Based on data in DEIS Tables J-5 and J-6, the Nevada Agency for Nuclear Projects has calculated the probable SNF and HLW volume flows along each major cross-country route to Yucca Mountain.

DOE contractors evaluated a preferred highway route to Yucca Mountain from California and Utah, I-15 to US95 via the new Las Vegas Beltway, and six alternative highway routes. Under DOE's mostly truck scenario, about 12,900 truck shipments (13% of the total) travel through California over 39 years, an average of just under 1 truck per day. (See Table 1) Under four of the six alternative routing scenarios, all 96,000 truck shipments travel through San Bernardino County, an average of about six shipments per day. The primary routes from California reactors are I-5, I-10, and I-210 through the Los Angeles metropolitan area to I-15, joined by out-of-state shipments on I-10 and I-40 at San Bernardino and Barstow.

DOE did not identify a preferred route rail, but evaluated four routing options for potential new rail spurs in Nevada. Under DOE's mostly rail scenario, the number of shipments through California ranges from about 1,300 to 4,100, an average of 1 to 2 shipments per week over four decades, depending on rail spur location. (See Tables 2, 3, 4, & 5) Primary rail routes include the UP lines through Sacramento, Roseville, Fresno, Los Angeles, San Bernardino, and Barstow; and the BNSF lines through Riverside and San Bernardino. In addition to these rail shipments, there would also be 44 truck shipments from Humboldt Bay on I-5 to I-15.

Nevada Agency for Nuclear Projects staff and contractors have critically reviewed DOE's shipment scenarios and routing assumptions. Based on these analyses, Nevada believes that the maximum credible number of truck shipments through California is about 74,000 over 39 years, an average of about 5 trucks per day. (See Table 6) Nevada believes the most likely national transportation scenario will involve each reactor shipping by truck or by rail according to its current capabilities, and a consolidated southern routing strategy which concentrates shipments on I-40 and the BNSF and UP mainlines through Arizona. Under Nevada's current capabilities scenario, California would be traversed by a total of 26,400 truck shipments and 9,800 rail shipments, a combined average of about 2.5 shipments per day over 39 years. (See Tables 7 & 8)

Nevada's comprehensive comments on transportation safety and security are available on the web at www.state.nv.us/nucwaste.