STATEMENT OF ANNE PEIRCE
NEVADA COMMISSION ON NUCLEAR PROJECTS

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

PRESENTED AT THE PUBLIC HEARING
IN RENO, NEVADA
DECEMBER 1, 1999

    My name is Anne Peirce, and I am here today both as a member of the Nevada Commission on Nuclear Projects and as a long-time resident of northern Nevada. I was appointed to the Commission in 1985 by Governor Bryan and have been actively involved with the Yucca Mountain program for over a decade.

    While the Commission on Nuclear Projects has studied and commented on numerous issues involving the federal high-level radioactive waste program over the years, I would like to focus my remarks today on three areas of concern in the draft Environmental Impact Statement.

    First, over the past few months, the Commission on Nuclear Projects has heard comments from affected local governments that DOE has ignored locally generated data and information in preparing the draft EIS. Several counties have apparently provided DOE with up to date information on demographics, highway accident rates, road conditions, emergency preparedness conditions, socioeconomic conditions, and other areas that were not utilized in the draft EIS. This is a serious oversight on DOE's part and calls into question the adequacy of the analyses contained in the draft EIS.

    Second, the overall treatment of spent nuclear fuel and high-level radioactive waste transportation in the draft EIS is deficient. It is unconscionable that a document of this importance and with such wide-ranging import does not contain clearly identified national highway and rail shipping routes for moving thousands of tons of highly radioactive wastes from reactor locations around the country to the proposed repository. It is clear from the analyses contained in chapter 6 of the draft EIS and in Appendix J that a point-to-point analysis, including a route-specific evaluation, was carried out by DOE contractors. Nowhere in the document, however, are the routes that would be used for transporting waste to a Yucca Mountain facility described or identified.

    The failure to disclose shipping routes effectively keeps members of the public in states and communities affected by the proposed action from having access to information essential for their participation in the National Environmental Policy Act process. This deficiency alone is sufficient to require that the draft EIS be withdrawn and reissued in a form that permits full and informed public involvement, as clearly intended by NEPA.

    While the draft EIS does discuss specific highway and rail shipping routes in Nevada, it is nevertheless deficient in another important way. The draft document does not contain analyses of routes and modes sufficient to support the identification of preferred alternatives. This is true for highway routes, rail spur corridors, and modal choices (including heavy-haul intermodal alternatives). Nevertheless, the statement is made in several places that the draft EIS is intended to support future decisions regarding the selection of preferred routes and modes of transport in Nevada.

    I submit that DOE cannot have it both ways. Either the draft EIS contains sufficient information and analyses to clearly identify and justify the selection of preferred transportation alternatives or the document is deficient and must be redone. DOE has been putting off decision regarding the shipment of spent fuel and high-level waste since the initial Yucca Mountain Environmental Assessment was issued in 1985. There is simply no excuse for not disclosing preferred transportation alternatives as part of this Environmental Impact Statement.

    As a State official and also as a northern Nevada resident, I am very concerned that the draft EIS does not deal honestly and comprehensively with potential transportation impacts to the Reno-Spark metropolitan area and northern Nevada in general. Given the rail spur that is proposed to be constructed from just east of Carlin to Yucca Mountain, it is very likely that the Reno area will experience shipments of dangerous spent fuel from California and perhaps Oregon and Washington as well along the Union Pacific Rail Line through the center of town. Yet, the draft EIS does not address this issue; it does not evaluate the potential impacts to the Reno area and northern Nevada; and it does not assess the costs of adequately preparing for accidents or other emergencies involving such shipments, including the potential for terrorism and sabotage occurring in or near Reno.

    On final point. The draft EIS treats Native American issues and concerns in a manner that is not only inadequate, but also condescending and insulting. While acknowledging that there could be impacts to Native American cultural sites along rail spur routes or at Yucca Mountain, the draft document completely ignores wider issues and impacts to Native peoples and communities. The draft includes a discussion of the Native American "perspective" on the project, but then proceeds to discount the viewpoint expressed and goes on to conclude that no significant impacts to Native Americans will occur, even though no substantive impact assessment work has been done in any of the Native communities potentially affected by the facility or by transportation routes.

    In closing, I would like to join the Governor, congressional delegation, and others in urging DOE to abandon the ill-conceived and potentially devastating Yucca Mountain project and choose a realistic no-action alternative as the preferred alternative in the final EIS.

    Thank you.


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