STATEMENT OF ROBERT R. LOUX, EXECUTIVE DIRECTOR,
NEVADA AGENCY FOR NUCLEAR PROJECTS
OFFICE OF THE GOVERNOR
TO THE U.S. DEPARTMENT OF ENERGY
OFFICE OF CIVILIAN RADIOACTIVE WASTE MANAGEMENT
REGARDING THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR A GEOLOGIC REPOSITORY FOR THE DISPOSAL OF SPENT
NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE AT YUCCA MOUNTAIN, NYE COUNTY, NEVADA
PRESENTED AT THE PUBLIC HEARING
IN CARSON CITY, NEVADA
DECEMBER 2, 1999
The State of Nevada's review of the draft Environmental Impact Statement (EIS) for the proposed nuclear waste repository at Yucca Mountain finds that the document continues the pattern of bias and inappropriately favorable interpretations of data that has characterized the federal high-level radioactive waste program from the beginning. The State believes the draft EIS to be both legally and substantively deficient for a number of reasons:
The draft EIS does not contain an accurate or adequate description of the project;
It postulates a "no action" alternative that is entirely unrealistic and unreasonable;
It fails to adequately evaluate the health, safety, and environmental impacts of a program that will intentionally - as part of the so-called waste isolation strategy - contaminate a groundwater source that is currently, and will be in the future, used by people for drinking, food production, and other needs;
It fails to adequately assess cumulative impacts from past, current, and future activities at the Nevada Test Site (NTS);
It completely ignores the potential for major and widespread socioeconomic impacts from the project, both in Nevada and in cities and communities throughout the nation; and
It fails to identify spent fuel and high-level waste shipping modes and routes in a way that permits people in affected communities to participate in the review and public comment process.
Despite extensive and compelling research findings by the State of Nevada, independent researchers, and even DOE's own contractors, the draft EIS fails to adequately analyze and evaluate potential socioeconomic impacts the Yucca Mountain project would have on the State of Nevada and affected local communities. For example, the draft EIS ignores the significant fiscal impacts that would accrue to State and local governments should this project go forward. A June 1998 report prepared for the Agency for Nuclear Projects found that costs to just 4 of the most affected State agencies to prepare for the thousands of shipments of spent fuel and HLW that would have be made to a repository could exceed $400 million in the first year alone. Yet, nowhere in the EIS are such impacts assessed, nor are similar costs and impacts to affected local governments addressed.
The draft EIS also ignores an extensive body of research that clearly demonstrates the potential for substantial and sustained impacts to Nevada's visitor-dependent economy should the Yucca Mountain project be implemented. Such impacts include the potential for significant reductions in tourist visits, substantial negative effects on property values along high-level waste shipping routes, as well as impacts on the State's ability to attract conventions, to entice new businesses, and to diversify the economy.
The State of Nevada believes that the draft EIS that is the subject of this hearing today is so deficient as to require its withdrawal and the initiation of a whole new EIS process, beginning with scoping for an accurately-described project and comparison with a reasonable and realistic no action alternative.