NOVEMBER 9, 1999

The Nevada Agency for Nuclear Projects will be submitting detailed written comments on all aspects of repository transportation impacts to the U.S Department of Energy (DOE) by the end of the public review period in February 2000. Nevada's draft transportation comments will be available about December 20, 1999 on our website at

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 shipment modes and routes, risks associated with legal weight truck (LWT) transport, and vulnerability of shipments to human initiated events including terrorism and sabotage. At upcoming hearings we will address radiological health effects of routine transportation, the risk of severe accidents involving loss of shielding and release of radioactive materials, rail spur construction and operations, impacts on Native American lands and cultural resources, and social and economic impacts of public perception of transportation risks.

Today our comments focus on heavy haul truck (HHT) transportation. The DEIS defines HHTs as "vehicles DOE would use on public highways to move spent nuclear fuel or high-level radioactive waste shipping casks designed for a railcar." [p. 2-9] The DEIS proposes use of HHTs to transport up to 19,845 rail casks of SNF and HLW from an intermodal transfer station in Nevada to the repository, along routes ranging in length from 114 to 331 miles. [p. 2-54] If DOE uses dual-purpose or disposable canisters, HHTs would return the empty shipping casks from the repository to the intermodal transfer station. [Pp. 2-8, 2-31] The DEIS also proposes using HHTs to originate rail cask shipments from 5 to 19 reactor sites, on routes ranging from 3.7 miles to 36.6 miles. [Pp. J-11, J-31 to J-32]

As pictured in the DEIS [p. 2-53], heavy rail casks would require special truck trailers about 150 feet long, supported by about 14 axles. With a diesel tractor in front and in back, the HHT rig would be about 220 feet long, or two-thirds the length of a football field. HHTs would be 10-12 feet wide, stand 15 feet above the road surface, and weigh up to 250 tons loaded. [p. 6-5] The DEIS envisions such HHTs travelling at an average speed of 20 to 30 miles per hour. State of Nevada permits would restrict HHT operations to weekdays during daylight hours. [p.2-53] There would be an average of 11 loaded HHT shipments per week, [p. 6-86] and 11 return shipments, every week for up to four decades.

The DEIS fails to demonstrate the feasibility of HHT transportation from an intermodal transfer station in Nevada to the proposed repository. In the United States there is no experience with long-distance HHT transportation of SNF or HLW, and only limited experience moving smaller rail casks (70 tons loaded weight) short distances by truck. There is only limited experience in Europe with short HHT movements of large rail casks. There is no experience anywhere moving SNF hundreds of miles by HHT through mountainous terrain. According to the Nevada Department of Transportation (NDOT), Nevada has permitted only two comparable HHT movements of any cargo during the past three years, both large mining autoclaves.

The DEIS discussion of HHT operations is deficient. Preliminary analysis by NDOT suggests that the total length of an HHT convoy including escort vehicles will be about 350 feet, and escorts will also be required for return shipments. On any given day of operations, there could be two to four HHTs travelling both ways along any route. No evidence is offered to support the 20 to 30 miles per hour average speed assumption. If actual average speeds are 10 to 15 miles per hour, traffic impacts would be exacerbated and overnight parking areas could be required on all identified routes. Even at 20 to 30 miles per hour, the DEIS has severely underestimated the adverse impact on normal traffic flows along HHT routes, considering convoy length and frequency. No evidence is offered on HHT turning radius requirements, which may necessitate shutting down certain intersections and road segments to allow HHT passage. There is no discussion of HHT in-transit refueing requirements, and no meaningful discussion of the safety, security, and perceived risk aspects of HHT overnight parking.

The DEIS discussion of HHT safety issues is also deficient. Because of the lack of actual experience with long distance HHT shipments, no meaningful empirical data is available to support the DEIS assertion that accident risks "are low for all five [route] alternatives." [p. 6-96] HHT operations on the routes identified in the DEIS may experience substantially higher accident frequencies and consequences. For example, using Nevada average accident rates, and projected shipment-miles for DOE's Module 2 scenario, the expected number of HHT accidents on the Caliente route would be about 24 (12 loaded, 12 empty) over 39 years. The severity and consequences of accidents could be greater because of unique local hazards. Steep upgrades and downgrades (especially in combination with horizontal curves less than 800 feet radius) and critical side slopes and steep drop-offs (common near the summits of mountain passes) could subject casks to extreme accident impact forces and make emergency response, cask recovery, and post-accident cleanup difficult. Such conditions appear to exist near Oak Springs Summit on US 93, near Hancock Summit on SR 375, and at several other locations along the Caliente HHT route.

A major deficiency in the DEIS HHT safety analysis involves the consequences of accidents involving military aircraft. The DEIS only evaluates aircraft accidents relative to intermodal transfer stations, and fails to consider the impacts on facilities and shipping casks of military ordinance and practice bombs used in training missions. The DEIS analysis is limited to the penetration capability of jet engines and engine shafts as falling projectiles. [p. J-97] DOE's 1986 Yucca Mountain environmental assessment (EA) correctly identified the potential vulnerability of rail and truck shipments to military aircraft accidents. All of the HHT routes identified in the DEIS are potentially vulnerable to military aircraft using the Nellis Air Force Base and Bombing Ranges. The DEIS must specifically evaluate the consequences of aircraft accidents involving military ordinance designed to destroy tanks and fortified installations. Further, the DEIS should also evaluate the potential impacts of military aircraft accidents involving practice weapons, including steel-tipped concrete dummy bombs weighing up to a ton. Even dummy weapons may have a greater destructive capability than the jet engine projectiles evaluated in the DEIS.

The DEIS generally fails to identify and evaluate credible HHT routing options. Nevada acknowledges that DOE has accurately classified the Caliente-Chalk River HHT route as a "non-preferred alternative" in response to national security issues raised by the Air Force. [p. 6-110] Since concurrence by the Secretary of the Air Force would be required, DOE should eliminate this route from further consideration. DOE's other HHT route options are unrealistic and unwise. The DEIS continues to consider HHT routes using I-15, the Las Vegas Beltway, and US 95 through Las Vegas, in spite of repeated advice from Clark County and state agencies that these routes are not even acceptable for LWT shipments. In 1994, NDOT notified the California Highway Patrol that: "Because I-15 goes through the heart of Las Vegas, Nevada is interested in selecting a preferred route bypassing Las Vegas." Absent action by California to designate SR 127 or other routes avoiding I-15 into Las Vegas, NDOT stated its intention to "recommend to the State Transportation Board the designation of Nevada SR-160 as the preferred route and to undesignate I-15 between the Utah-Nevada Stateline and Las Vegas as a preferred route." DOE should eliminate HHT routes through Las Vegas from further consideration.

The HHT routes identified in the DEIS do not meet U.S. Nuclear Regulatory Commission (NRC) safeguards criteria. A curious deficiency in the DEIS HHT routing analysis is DOE's apparent ignorance of the NRC safeguards route approval process and criteria. Advance route approvals are part of a safeguards system designed to "[m]inimize the possibilities for radiological sabotage of spent fuel shipments, especially within heavily populated areas...".[ 10CFR '73.37(a)(1)(i)] In 1980, NRC issued a regulatory guidance document [NUREG-0561, Rev. 1] which identified five types of route characteristics that receive special consideration when Commission staff review requests for route approval : (1) routes through highly populated areas; (2) routes which would place the shipment or the escort vehicle in a significantly tactically disadvantageous position (for example, tunnels which would prevent the escort vehicle from maintaining continuous surveillance of the shipment vehicle); (3) routes with marginal safety design features (for example, two-lane routes, absence of guard rails, etc.); (4) routes with limited rest and refueling locations; and (5) routes where responses by local law enforcement agencies, when requested, would not be swift or timely. None of the HHT routes identified in the DEIS meet the safeguards routing criteria established by the NRC. NRC has accepted Nevada's petition for rulemaking, which requests a further strengthening of the advance route approval requirements.

The DEIS does not adequately evaluate the radiological impacts of routine HHT transportation using the Caliente route. The DEIS states that HHT shipments could routinely use existing roadways through Tonopah and Goldfield. [Pp. 6-100, J-84, and J-88] The State of Nevada challenges this assertion, but if we accept it for purposes of analysis, the DEIS appears to significantly underestimate HHT routine radiation exposures to the general public in Tonopah, in Goldfield, and possibly in Beatty. The RADTRAN model, using the assumptions described in the DEIS, [Pp. J-39 to J-42] is not sufficiently sensitive to local conditions and probable HHT operating characteristics. DOE must recalculate the annual and cumulative collective dose and maximum individual dose, assuming that each HHT shipment stops for 2 -5 minutes at the intersection of US 6 and US 95, and travels through Tonopah and Goldfield at an average speed of 5 miles per hour. The analysis must consider the actual location of all occupied buildings within mile of the route. The analysis must accurately reflect the actual population within mile of the route during daylight hours on week days, including children in schools and nonresidents in hotels and commercial establishments. The State of Nevada will prepare its own reassessment of routine radiation exposures using these assumptions. Preliminary indications are that numerous individuals could receive annual doses from HHT operations equal to ten percent or more of annual background radiation exposures.

The DEIS does not properly evaluate a range of costs for required infrastructure upgrades along the Caliente HHT route. Aside from construction of a short bypass in Beatty, the DEIS assumes that the Caliente HHT route will require only moderate pavement upgrades turnouts every 20 miles. [p. J-89] Preliminary analysis by NDOT indicates that the life-cycle costs of such upgrades may be $450-500 million. Additional upgrades may be necessary for safety and traffic control, as well as to reduce routine radiological exposures and perceived risk impacts. NWPO has identified 13 route segments, with a total length of 92 miles, where slow lanes would likely be required on both sides of the road, at a cost of at least $100 million in addition to pavement upgrades. DOE must reexamine its minimum infrastructure upgrade assumptions and costs. A bounding analysis should estimate the cost of constructing slow traffic lanes on both sides of the road for the entire 331mile route. DOE should also investigate the costs and benefits of constructing bypasses to avoid the US 6 intersection with US 95 in Tonopah and the extreme right turn on US 95 in Goldfield.