TESTIMONY OF ROBERT J. HALSTEAD
TRANSPORTATION ADVISOR TO THE
STATE OF NEVADA AGENCY FOR NUCLEAR PROJECTS

BEFORE THE NEVADA LEGISLATURE'S
SENATE COMMITTEE ON TRANSPORTATION
REGARDING SENATE JOINT RESOLUTION NO. 4

MR. CHAIRMAN AND MEMBERS OF THE COMMITTEE, THANK YOU FOR THE OPPORTUNITY TO TESTIFY TODAY. FOR THE RECORD, MY NAME IS ROBERT HALSTEAD. I AM THE HIGH-LEVEL RADIOACTIVE WASTE TRANSPORTATION ADVISOR FOR THE NEVADA AGENCY FOR NUCLEAR PROJECTS. IN THAT CAPACITY, I HAVE BEEN INVOLVED WITH THE STUDY OF SPENT NUCLEAR FUEL AND HIGH-LEVEL NUCLEAR WASTE TRANSPORTATION ISSUES FOR OVER 13 YEARS. BETWEEN 1978 AND 1988, I WAS EMPLOYED IN A SIMILAR CAPACITY BY THE STATE OF WISCONSIN WHEN CANDIDATE SITES IN THAT STATE WERE UNDER CONSIDERATION FOR A GEOLOGIC REPOSITORY. I HAVE ALSO SERVED AS A CONSULTANT FOR THE STATES OF MINNESOTA, TENNESSEE, AND TEXAS.

I AM HERE TODAY AT THE REQUEST OF CHAIRMAN O'DONNELL. I HAVE ORGANIZED MY PREPARED TESTIMONY IN RESPONSE TO THE THREE QUESTIONS POSED IN CHAIRMAN O'DONNELL'S LETTER DATED MARCH 8, 2001.

LET ME PREFACE MY REMARKS BY NOTING THAT, FROM A TRANSPORTATION STANDPOINT, IT WOULD BE DIFFICULT FOR THE FEDERAL GOVERNMENT TO HAVE PROPOSED A MORE PROBLEMATIC SITE FOR A REPOSITORY THAN YUCCA MOUNTAIN. THE SITE LACKS RAIL ACCESS, HAS LIMITED HIGHWAY ACCESS, AND IS AFFECTED BY UNIQUE LOCAL CONDITIONS THAT INCREASE BOTH THE RADIOLOGICAL RISKS AND PERCEIVED RISKS OF NUCLEAR WASTE TRANSPORTATION. THE U.S. DEPARTMENT OF ENERGY (DOE) WAS FULLY AWARE OF THESE FACTS IN 1986. THE DECISION TO STUDY YUCCA MOUNTAIN AT ALL, GIVEN THE MAJOR TRANSPORTATION SHORTCOMINGS OF THE SITE, TYPIFIES THE SHORT-SIGHTED APPROACH THE DEPARTMENT HAS TAKEN WITH RESPECT TO SPENT FUEL AND HIGH-LEVEL WASTE SHIPMENT ISSUES, BOTH NATIONALLY AND IN NEVADA.

ANALYSIS OF THE HIGHWAY AND RAILROAD ROUTES WITHIN THE STATE OF NEVADA THAT THE U.S. DEPARTMENT OF ENERGY HAS CONSIDERED FOR TRANSPORTATION OF SNF AND HLW TO YUCCA MOUNTAIN

DOE IDENTIFIED AND EVALUATED POTENTIAL HIGHWAY AND RAIL ROUTES WITHIN THE STATE OF NEVADA IN 1986. DOE'S 1986 ENVIRONMENTAL ASSESSMENTS FOR YUCCA MOUNTAIN AND CANDIDATE SITES IN FOUR OTHER STATES CONCLUDED THAT YUCCA MOUNTAIN WAS THE WORST POSSIBLE LOCATION FROM A TRANSPORTATION PERSPECTIVE. DOE DOCUMENTED THAT YUCCA MOUNTAIN HAD THE POOREST ACCESS TO THE NATIONAL INTERSTATE HIGHWAY AND MAINLINE RAILROAD NETWORKS, AND THE MOST DIFFICULT RAIL ACCESS CONSTRUCTION REQUIREMENTS. AND THAT WAS IN 1986 WHEN DOE STILL CONSIDERED IT FEASIBLE TO CONSTRUCT A RAIL SPUR THROUGH THE LAS VEGAS VALLEY AND TO SHIP WASTE BY TRUCK OVER HOOVER DAM AND THROUGH THE SPAGHETTI BOWL.

DOE'S 1986 COMPARATIVE ANALYSIS ALSO SHOWED THAT SELECTION OF YUCCA MOUNTAIN WOULD RESULT IN THE HIGHEST CROSS-COUNTRY TRANSPORTATION REQUIREMENTS (MEASURED IN SHIPMENT-MILES), HIGHEST TOTAL TRANSPORTATION COSTS, AND THE HIGHEST PROJECTED NUMBER OF TRANSPORTATION ACCIDENT INJURIES AND FATALITIES.

DOE'S 1986 EA IDENTIFIED THE FOLLOWING PRIMARY HIGHWAY ROUTES TO YUCCA MOUNTAIN VIA LAS VEGAS:

(1) I-15 SOUTHBOUND FROM THE ARIZONA-NEVADA STATE LINE TO US 95 IN LAS VEGAS;

(2) US 93 NORTHBOUND FROM THE ARIZONA-NEVADA STATE LINE TO US 95 IN LAS VEGAS;

(3) I-15 NORTHBOUND FROM THE CALIFORNIA-NEVADA STATE LINE TO US 95 IN LAS VEGAS; AND

(4) US 95 NORTHBOUND FROM LAS VEGAS TO AMARGOSA VALLEY.

DOE'S 1986 EA ALSO IDENTIFIED THREE HIGHWAY ROUTES WHICH AVOIDED THE LAS VEGAS AREA:

(5) I-80 BETWEEN THE CALIFORNIA-NEVADA STATE LINE AND WINNEMUCCA;

(6) VARIOUS COMBINATIONS OF US 95, US 95A, SR 305, US 50, SR 376, AND US 6, BETWEEN I-80 AND AMARGOSA VALLEY; AND

(7) SR 373 FROM THE CALIFORNIA-NEVADA STATE LINE TO AMARGOSA VALLEY.

DOE'S 1986 EA ASSUMED CONSTRUCTION OF A NEW, 100-MILE LONG RAIL ACCESS SPUR ORIGINATING AT DIKE SIDING, NORTH OF LAS VEGAS, TRAVELING NORTH OF, AND ROUGHLY PARALLEL TO US 95, THROUGH INDIAN SPRINGS AND MERCURY TO AMARGOSA VALLEY. DOE IDENTIFIED TWO EXISTING RAIL ROUTES TO DIKE SIDING: THE UNION PACIFIC MAINLINE WESTBOUND FROM UTAH, AND THE UNION PACIFIC MAINLINE EASTBOUND FROM CALIFORNIA.

DOE CONDUCTED A NUMBER OF HIGHWAY AND RAILROAD ROUTING STUDIES BETWEEN 1988 AND 1998. THE RESULTS OF THESE STUDIES WERE CONSIDERED IN SELECTING THE ROUTES LISTED IN DOE'S 1999 DRAFT YUCCA MOUNTAIN ENVIRONMENTAL IMPACT STATEMENT (DEIS). [PAGES 6-41 TO 6-43]

THE 1999 DEIS IDENTIFIED A PREFERRED NEVADA HIGHWAY ROUTE FOR LEGAL-WEIGHT TRUCK [LWT] SHIPMENTS TO YUCCA MOUNTAIN: "DOE HAS ASSUMED THAT SHIPMENTS OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE WOULD ENTER NEVADA ON I-15 FROM EITHER THE NORTHEAST OR SOUTHWEST. THE ANALYSIS ASSUMED THAT SHIPMENTS TRAVELING ON I-15 FROM THE NORTHEAST WOULD USE THE NORTHERN LAS VEGAS BELTWAY TO CONNECT TO U.S. 95 AND CONTINUE TO THE NEVADA TEST SITE. SHIPMENTS FROM THE SOUTHWEST ON I-15 WOULD USE THE SOUTHERN AND WESTERN LAS VEGAS BELTWAY TO CONNECT TO U.S. 95 AND CONTINUE TO THE NEVADA TEST SITE."[PAGES J-93 TO J-95]

THE DEIS ALSO IDENTIFIED SEVEN POTENTIAL ALTERNATIVE ROUTES TO YUCCA MOUNTAIN, BASED ON A 1989 STUDY BY THE NEVADA DEPARTMENT OF TRANSPORTATION:

ROUTE A - SOUTHBOUND FROM UTAH, LEAVING I-80 AT WEST WENDOVER ON U.S. 93A, U.S. 93, U.S. 6, SR 318, U.S. 93, I-15, CRAIG ROAD, AND U.S. 95;

ROUTE B - SOUTHBOUND FROM UTAH, LEAVING I-80 AT WEST WENDOVER ON U.S. 93A, U.S. 93, U.S. 6, AND U.S. 95;

ROUTE C - NORTHBOUND FROM BAKER, CALIFORNIA, ON SR 127, SR 373 AND U.S. 95;

ROUTE D - NORTHBOUND FROM BAKER, CALIFORNIA, ON I-15 TO SR160 AND U.S. 95;

ROUTE E - NORTHBOUND FROM NEEDLES, CALIFORNIA, ON U.S. 95, SR 164, I-15, SR 127, SR 373, AND U.S. 95;

ROUTE E VARIATION - NORTHBOUND FROM NEEDLES, CALIFORNIA, ON U.S. 95, SR 164, I-15, SR 160 AND U.S. 95; AND

ROUTE F - NORTHBOUND FROM NEEDLES, CALIFORNIA, ON I-40, I-15, SR 160, AND U.S. 95.

THE DEIS IDENTIFIED FIVE POTENTIAL CORRIDORS FOR CONSTRUCTION OF A NEW RAIL ACCESS SPUR TO YUCCA MOUNTAIN. FOUR OF THESE CORRIDORS WOULD ORIGINATE FROM LOCATIONS ALONG THE UNION PACIFIC'S LOS ANGELES-SALT LAKE CITY MAINLINE THROUGH SOUTHERN NEVADA: JEAN, VALLEY SIDING [MODIFIED], CALIENTE, AND CALIENTE-CHALK MOUNTAIN. THE FIFTH CORRIDOR, IDENTIFIED AS THE CARLIN OPTION, WOULD ORIGINATE AT BEOWAWE IN EUREKA COUNTY ON THE UNION PACIFIC'S SAN FRANCISCO-SALT LAKE CITY MAINLINE THROUGH NORTHERN NEVADA.

THE DEIS ALSO IDENTIFIED FIVE POTENTIAL HIGHWAY ROUTES FOR HEAVY HAUL TRUCK (HHT) TRANSPORT OF LARGE RAIL CASKS FROM THREE PROPOSED INTERMODAL TRANSFER STATIONS IN SOUTHERN NEVADA. DOE'S PROPOSED LARGE-SCALE USE OF HHTS FOR LONG-DISTANCE SNF TRANSPORT ON PUBLIC HIGHWAYS IS ENTIRELY UNPRECEDENTED. THE AGENCY SUBMITTED DETAILED, CRITICAL COMMENTS ON HHT TRANSPORT AS PART OF THE DEIS REVIEW PROCESS. STATE REVIEWERS OF THE DRAFT EIS CONSIDERED THE HHT PROPOSAL TO BE OPERATIONALLY INFEASIBLE AND WITHOUT CREDIBILITY, GIVEN THE MASSIVE IMPACTS SUCH SHIPMENTS WOULD HAVE ON STATE HIGHWAYS.

ADVANTAGES AND DISADVANTAGES OF TRANSPORTATION ALTERNATIVES

THE NEVADA AGENCY FOR NUCLEAR PROJECTS HAS STUDIED DOE'S POTENTIAL HIGHWAY AND RAIL ROUTES FOR SHIPPING SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE TO A PROPOSED REPOSITORY AT YUCCA MOUNTAIN. ALL OF THE ROUTES STUDIED HAVE MAJOR PROBLEMS AND DRAWBACKS. THE AGENCY BELIEVES THAT THERE IS NO TECHNICALLY DEFENSIBLE BASIS FOR SUPPORTING ANY POTENTIAL HIGHWAY OR RAIL ROUTE AT THE PRESENT TIME.

SEVERAL OF THE POSSIBLE HIGHWAY ROUTES IDENTIFIED BY DOE PRIOR TO 1999 (US 93 ACROSS HOOVER DAM, AND I-80, US 95, US 95A, SR 305, US 50, AND SR 376 IN NORTHERN NEVADA) WERE DROPPED FROM CONSIDERATION IN THE DEIS. TWO OTHER ROUTES (NDOT ROUTES C AND E) CANNOT BE USED WITHOUT APPROVAL BY THE STATE OF CALIFORNIA AND/OR SAN BERNARDINO COUNTY, BOTH OF WHICH HAVE ADAMANTLY OPPOSED DESIGNATION OF SR 127 AND NIPTON ROAD AS ALTERNATIVE ROUTES.

NDOT ROUTE A, WHICH PROPOSED USE OF CRAIG ROAD IN CLARK COUNTY, WAS UNREALISTIC IN 1989 AND IS EVEN MORE UNREALISTIC IN 2001. THIS LEAVES FOUR POTENTIAL HIGHWAY ROUTES UNDER CONSIDERATION: DOE'S PREFERRED ROUTE (I-15, LAS VEGAS BELTWAY, AND US 95); I-15 AND US 95 VIA THE SPAGHETTI BOWL (THE ONLY ROUTE CURRENTLY AVAILABLE UNDER US DOT REGULATIONS); I-15, SR 160, AND US 95; AND NDOT ROUTE B SOUTH AND WEST FROM I-80 AT WEST WENDOVER .

THE AGENCY SUBMITTED DETAILED COMMENTS TO DOE REGARDING THE DISADVANTAGES OF USING ANY PORTION OF I-15 OR US 95 THROUGH LAS VEGAS FOR SHIPMENTS OF SNF OR HLW. USE OF THESE ROUTES WOULD RESULT IN UNACCEPTABLE ROUTINE RISKS, ACCIDENT RISKS, TERRORISM RISKS, AND STIGMA-INDUCED SOCIOECONOMIC RISKS. THE STATE AND CLARK COUNTY HAVE ALSO QUESTIONED WHETHER DOE CAN LEGALLY USE THE YET-TO-BE- COMPLETED LAS VEGAS BELTWAY (I-215).

HOWEVER, DOE'S PREFERRED ROUTE (I-15, LAS VEGAS BELTWAY, AND US 95) WAS IDENTIFIED FOLLOWING THE US DOT HIGHWAY ROUTING GUIDELINES BECAUSE IT MAXIMIZES USE OF THE INTERSTATE HIGHWAY SYSTEM; MAXIMIZES USE OF MULTIPLE-LANE, DIVIDED HIGHWAYS; UTILIZES AN AVAILABLE INTERSTATE URBAN BYPASS; AND MINIMIZES TIME AND DISTANCE. MOREOVER, DOE'S DEIS INCLUDES A COMPARATIVE SAFETY ANALYSIS, USING THE RADTRAN MODEL, WHICH SUPPORTS USE OF THE PREFERRED ROUTE BY CALCULATING LOWER NATIONAL RADIOLOGICAL AND NON-RADIOLOGICAL IMPACTS COMPARED TO THE OTHER AVAILABLE ROUTES. THE AGENCY HAS CHALLENGED DOE'S APPLICATION OF THE US DOT ROUTING GUIDELINES AND THE METHODOLOGY OF DOE'S SAFETY ANALYSIS IN ITS COMMENTS ON THE DEIS, AND HAS PRIORITIZED THESE ISSUES FOR POSSIBLE LITIGATION UNDER N.E.P.A.

THE AGENCY HAS ALSO EVALUATED POTENTIAL SNF AND HLW SHIPMENTS ON NDOT ROUTE D, I-15 AND SR 160 (BLUE DIAMOND ROAD) THROUGH THE RAPIDLY GROWING ENTERPRISE-ARDEN AREA OF CLARK COUNTY AND THROUGH THE CITY OF PAHRUMP IN NYE COUNTY. THIS ROUTE HAS MANY OF THE SAME DISADVANTAGES AS SHIPMENTS THROUGH LAS VEGAS. RADIOLOGICAL RISKS AND ADVERSE SOCIOECONOMIC IMPACTS WOULD BE MAJOR CONCERNS. CERTAIN SEGMENTS OF THIS ROUTE, INCLUDING THE MOUNTAIN SPRINGS PASS AND FLASH FLOOD AREAS BETWEEN THE SPRING MOUNTAINS AND PAHRUMP, ARE ESPECIALLY HAZARDOUS DURING SEVERE WEATHER. RECREATIONAL USE OF RED ROCK CANYON AND OTHER AREAS WITHIN THE TOIYABE NATIONAL FOREST WOULD LIKELY BE ADVERSELY AFFECTED. SR 160 IS CURRENTLY BEING UPGRADED, BUT VEHICLE TRAFFIC APPEARS TO BE GROWING FASTER THAN THE CAPACITY INCREASES.

THE AGENCY HAS ALSO EVALUATED NDOT ROUTE B, WHICH ENTERS NEVADA FROM I-80 AT WEST WENDOVER. THE NDOT B ROUTE IS NOT, IN OUR OPINION, AN ACCEPTABLE ALTERNATIVE TO ROUTES THROUGH CLARK COUNTY. EVEN IF THIS ROUTE WERE DESIGNATED FOR TRUCK SHIPMENTS FROM EASTERN REACTORS, TRUCK SHIPMENTS FROM 12 REACTORS IN 7 STATES (AL, AR, AZ, CA, LA, MS, & TX) COULD STILL BE ROUTED THROUGH CLARK COUNTY. THESE 12 REACTORS COULD ACCOUNT FOR UP TO 12,870 SHIPMENTS OVER 38 YEARS, AN AVERAGE OF ALMOST ONE SHIPMENT PER DAY.

MOREOVER, THE AGENCY'S EVALUATION OF THE 'B' ROUTE HAS IDENTIFIED SERIOUS DISADVANTAGES. THE MOST COMPELLING DISADVANTAGE IS THE POTENTIAL FOR SIGNIFICANT RADIOLOGICAL RISKS AND ADVERSE SOCIOECONOMIC IMPACTS ON CITIES AND TOWNS ALONG THE ROUTE, INCLUDING WEST WENDOVER, MCGILL, ELY, TONOPAH, GOLDFIELD, AND BEATTY. RESIDENTIAL AREAS AND DOWNTOWN AND SUBURBAN BUSINESS DISTRICTS WOULD BE DIRECTLY IMPACTED. IN NUMEROUS INSTANCES, COMMERCIAL BUILDINGS, DWELLINGS, AND SCHOOLS ARE LOCATED WITHIN 40 METERS (130 FEET) OF THE ROUTE. IN ELY, TONOPAH, BEATTY, AND GOLDFIELD, SOME BUILDINGS ARE LOCATED ONLY 6 TO 10 METERS (20 TO 33 FEET) FROM THE ROUTE. THIS EXTRAORDINARY PROXIMITY TO A HEAVILY USED SPENT FUEL SHIPPING ROUTE COULD EXPOSE INDIVIDUALS AT SOME LOCATIONS TO ANNUAL DOSES OF 150 MREM TO 260 MREM, EQUIVALENT TO ABOUT 40% TO 60% OF THE AVERAGE ANNUAL BACKGROUND RADIATION DOSE. WHILE THE PRECISE HEALTH EFFECTS OF SUCH REPEATED EXPOSURES ARE NOT FULLY UNDERSTOOD, THERE CAN BE NO DOUBT THAT THESE ROUTINE EXPOSURES WOULD IMPOSE SIGNIFICANT AND PROBABLY UNMITIGABLE ADVERSE SOCIOECONOMIC IMPACTS ON INDIVIDUALS AND COMMUNITIES.

RURAL SEGMENTS OF THE NDOT B ROUTE ARE ALSO DISADVANTAGEOUS. THE ROUTE IS ABOUT 400 MILES LONG, MAINLY TWO-LANE, AND FREQUENTLY CHARACTERIZED BY SHARP CURVES, STEEP GRADES, NARROW ROAD SHOULDERS, AND ABSENCE OF GUARD RAILS. MOUNTAIN PASSES ALONG THE ROUTE, SUCH AS MURRAY SUMMIT (ELEVATION 7,300) IN WHITE PINE COUNTY, CAN BECOME TREACHEROUS OR IMPASSIBLE DURING WINTER STORMS. LONG STRETCHES OF THIS ROUTE (UP TO 60 MILES IN LENGTH) FAIL TO MEET THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) ROUTE APPROVAL CRITERIA FOR SAFEGUARDING SHIPMENTS FROM SABOTAGE AND TERRORISM, INCLUDING MARGINAL SAFETY DESIGN FEATURES, LIMITED REST AND REFUELING AREAS, LIMITED LOCAL LAW ENFORCEMENT RESPONSE CAPABILITIES, AND RECURRENT ROUTE FEATURES WHICH PLACE SHIPMENTS AND ESCORT VEHICLES IN A SIGNIFICANTLY TACTICALLY DISADVANTAGEOUS POSITION, INCREASING THE RISKS OF SABOTAGE AND TERRORIST ACTION.

THE DEIS IDENTIFIED FOUR POTENTIAL RAIL ACCESS CORRIDORS ORIGINATING FROM LOCATIONS ALONG THE UNION PACIFIC'S LOS ANGELES- SALT LAKE CITY MAINLINE THROUGH SOUTHERN NEVADA: JEAN, VALLEY MODIFIED, CALIENTE, AND CALIENTE-CHALK MOUNTAIN. ALL FOUR ROUTES SHARE ONE MAJOR DISADVANTAGE: POTENTIAL LARGE-SCALE RAIL SHIPMENTS OF SNF AND HLW (BETWEEN 7% AND 87% OF THE TOTAL) THROUGH DOWNTOWN LAS VEGAS ON THE UP MAINLINE BETWEEN TROPICANA AVENUE AND LAKE MEADE BOULEVARD. THE ENTIRE LAS VEGAS STRIP NORTH OF FLAMINGO AVENUE IS WITHIN ONE MILE OF THE UP MAIN LINE. SOUTH OF FLAMINGO, THE DISTANCE BETWEEN THE STRIP AND THE RAILROAD IS LESS THAN ONE AND ONE-HALF MILES. LARGE AREAS OF NORTH LAS VEGAS, AND VAST SUBURBAN AREAS NORTH AND SOUTH OF LAS VEGAS, ARE WITHIN TWO MILES OF THE RAILROAD.

THE ONE RAIL SPUR ROUTE WHICH AVOIDS LAS VEGAS, THE CARLIN CORRIDOR, WOULD RESULT IN LARGE-SCALE RAIL SHIPMENTS OF SNF AND HLW THROUGH CITIES AND TOWNS ALONG THE NORTHERN UNION PACIFIC RAILROAD, INCLUDING RENO, SPARKS, LOVELOCK, WINNEMUCCA, BATTLE MOUNTAIN, CARLIN, ELKO, AND WELLS.

DOE'S PROPOSED CARLIN ROUTE ORIGINATES AT BEOWAWE (ABOUT 23 MILES WEST OF CARLIN) IN EUREKA COUNTY, TRAVELS SOUTH THROUGH CRESCENT, GRASS, AND BIG SMOKEY VALLEYS, CROSSES US 95 BETWEEN TONOPAH AND GOLDFIELD, FOLLOWS US 95 AND THE WESTERN BOUNDARY OF THE NELLIS AIR FORCE RANGE THROUGH OASIS VALLEY, BEATTY WASH, AND FORTYNINE MILE WASH TO YUCCA MOUNTAIN. MAJOR UNRESOLVED ISSUES INCLUDE POTENTIAL ADVERSE IMPACTS ON PRIVATE LANDS (RESIDENCES, RANCHES, AND MINING CLAIMS), CRITICAL WILDLIFE HABITATS (BIGHORN SHEEP, ELK, PRONGHORN, AND MULE DEER), GROUNDWATER RESOURCES, AND WETLANDS.

POTENTIAL CONFLICTS WITH AIR FORCE ACTIVITIES ARE ALSO AT ISSUE. DOE'S 1986 EA IDENTIFIED PROXIMITY TO AIR FORCE BOMBING RANGES AS A UNIQUE LOCAL CONDITION THAT COULD THREATEN RADIOLOGICAL SAFETY. FIFTEEN YEARS LATER, DOE HAS STILL NOT ADDRESSED NEVADA'S CONCERNS ABOUT THE VULNERABILITY OF SNF SHIPPING CASKS TO MILITARY AIRCRAFT ACCIDENTS INVOLVING LIVE MUNITIONS AND DUMMY BOMBS.

DOE HAS CONSISTENTLY UNDERESTIMATED THE DIFFICULTY AND COST OF CONSTRUCTING A NEW RAIL LINE TO YUCCA MOUNTAIN. SELECTION OF THE CARLIN ROUTE (323 MILES IN LENGTH) OR EITHER OF THE CALIENTE ROUTES (319 AND 214 MILES LONG) WOULD CONSTITUTE THE LONGEST NEW RAIL CONSTRUCTION PROJECT IN THE UNITED STATES SINCE WORLD WAR I. CONSTRUCTION WOULD LIKELY REQUIRE 5 TO 7 YEARS, RATHER THAN THE 2.5 YEARS ESTIMATED BY DOE. LEGAL CHALLENGES COULD DELAY CONSTRUCTION FOR ANOTHER 5 TO 10 YEARS, CONSIDERING THE DIFFICULTY OF ENVIRONMENTAL REVIEWS AND APPROVALS, LAND ACQUISITION, AND NATIVE AMERICAN RIGHTS ISSUES.

DOE"S DEIS ESTIMATED THE TOTAL LIFE-CYCLE COST OF THE CARLIN ROUTE AT $753 MILLION (1997 DOLLARS), COMPARED TO $801 MILLION FOR THE CALIENTE ROUTE AND $566 MILLION FOR THE CALIENTE-CHALK MOUNTAIN ROUTE. AN INDEPENDENT COST ASSESSMENT OF THE CALIENTE ROUTE PREPARED FOR THE AGENCY FOUND THAT CONSTRUCTION ALONE WOULD COST ABOUT $1.9 BILLION (1996 DOLLARS), WITH TOTAL LIFE-CYCLE COSTS EXCEEDING $2.7 BILLION.

COMPARISON OF POSSIBLE MODAL MIXES AND ESTIMATED NUMBER OF SHIPMENTS

DOE'S DEIS CONSIDERED 2 SCENARIOS FOR TOTAL SHIPMENTS TO THE PROPOSED REPOSITORY. UNDER THE FIRST SCENARIO, SHIPMENTS OCCUR OVER 24 YEARS (2010 - 2034), AND TOTAL RECEIPTS ARE LIMITED TO 70,000 MTU ( 63,000 MTU OF CIVILIAN SNF AND 7,000 MTU OF DEFENSE HLW, DOE SNF, NAVAL SNF, AND CIVILIAN HLW). UNDER THE SECOND SCENARIO, SHIPMENTS OCCUR OVER 38 YEARS (2010 - 2048), AND TOTAL RECEIPTS ARE THE ENTIRE PROJECTED NATIONAL INVENTORY SNF AND HLW, 120,000 MTU ( 105,000 MTU OF CIVILIAN SNF AND 15,000 MTU OF DEFENSE HLW, DOE SNF, NAVAL SNF, AND CIVILIAN HLW).

THE AGENCY HAS USED DOE'S 38 YEAR SCENARIO FOR TRANSPORTATION IMPACT ASSESSMENT PURPOSES, ASSUMING THAT ALL PROJECTED SNF AND HLW WOULD BE SHIPPED TO THE PROPOSED YUCCA MOUNTAIN REPOSITORY. THE AGENCY HAS DECIDED TO USE DOE'S ESTIMATES OF PROJECTED SNF AND HLW INVENTORIES, ALTHOUGH IT IS POSSIBLE THAT THE TOTAL AMOUNT OF DEFENSE HLW REQUIRING GEOLOGIC DISPOSAL COULD BE SIGNIFICANTLY HIGHER.

DOE'S DEIS ALSO CONSIDERED TWO DIFFERENT MODAL MIX SCENARIOS FOR NATIONAL SHIPMENTS TO THE PROPOSED REPOSITORY. UNDER THE FIRST SCENARIO, DOE'S MOSTLY TRUCK SCENARIO, 77 CIVILIAN AND DOE SITES SHIP ALL SNF AND HLW BY LEGAL-WEIGHT TRUCK, EXCEPT FOR 300 RAIL SHIPMENTS OF NAVAL REACTOR SNF FROM IDAHO. UNDER THE SECOND SCENARIO, DOE'S MOSTLY RAIL SCENARIO, ALL 5 DOE SITES AND 63 CIVILIAN REACTOR SITES SHIP

ALL SNF AND HLW BY RAIL IN NEWLY DESIGNED, HIGH-CAPACITY CASKS. ONLY 9 CIVILIAN REACTOR SITES SHIP SNF BY LEGAL-WEIGHT TRUCK.

THE AGENCY PUBLISHED AN INDEPENDENT ASSESSMENT OF CIVILIAN REACTOR AND DOE SHIPPING SITE CAPABILITIES PREPARED BY PLANNING INFORMATION CORPORATION (PIC) IN 1996. BASED ON THE 1996 PIC REPORT, THE AGENCY CONCLUDED THAT DOE'S MOSTLY TRUCK SCENARIO IS CREDIBLE. ALL 77 SITES ARE CAPABLE OF SHIPPING SNF AND HLW IN LEGAL-WEIGHT TRUCK CASKS, ALTHOUGH SOME OLDER REACTOR SITES MAY NOT BE ABLE TO USE THE NEWLY-DESIGNED, HIGHER-CAPACITY (GA/4 & GA/9) TRUCK CASKS. HOWEVER, THE AGENCY CONCLUDED THAT DOE'S MOSTLY RAIL SCENARIO IS NOT CREDIBLE AT THE CURRENT TIME. THERE ARE PRESENTLY 32 CIVILIAN REACTOR SITES WHICH EITHER CANNOT SHIP BY RAIL, OR CAN ONLY SHIP BY RAIL UNDER THE MOST OPTIMISTIC ASSUMPTIONS, AND IN SOME CASES ONLY UNDER TOTALLY UNREALISTIC ASSUMPTIONS. THE AGENCY HAS THEREFORE DEVELOPED AN ADDITIONAL MODAL MIX SCENARIO, THE STATE OF NEVADA CURRENT CAPABILITIES SCENARIO.

UNDER DOE'S MOSTLY TRUCK SCENARIO, 99% OF TOTAL SNF AND HLW WOULD BE SHIPPED TO YUCCA MOUNTAIN BY LEGAL-WEIGHT TRUCK (LWT). DOE HAS ESTIMATED A TOTAL OF 96,000 LWT SHIPMENTS, AN AVERAGE OF 2,534 TRUCK SHIPMENTS PER YEAR, OR ABOUT 7 TRUCK SHIPMENTS PER DAY, OVER 38 YEARS. THERE WOULD ALSO BE AN AVERAGE OF 8 RAIL SHIPMENTS PER YEAR.

UNDER DOE'S MOSTLY RAIL SCENARIO, LESS THAN 10% OF TOTAL SNF AND HLW WOULD BE SHIPPED TO YUCCA MOUNTAIN BY LEGAL-WEIGHT TRUCK (LWT). DOE HAS ESTIMATED A TOTAL OF 3,700 LWT SHIPMENTS, AN AVERAGE OF 97 TRUCK SHIPMENTS PER YEAR, OR ABOUT 2 TRUCK SHIPMENTS PER WEEK, OVER 38 YEARS. THERE WOULD ALSO BE 19,800 RAIL SHIPMENTS, AN AVERAGE OF 521 RAIL SHIPMENTS PER YEAR.

UNDER THE STATE OF NEVADA CURRENT CAPABILITIES SCENARIO, 40% OF CIVILIAN SNF WOULD BE SHIPPED TO YUCCA MOUNTAIN BY LEGAL-WEIGHT TRUCK (LWT). THE REMAINING 60% OF CIVILIAN SNF AND ALL OTHER SNF AND HLW WOULD BE SHIPPED BY RAIL. THE AGENCY HAS ESTIMATED A TOTAL OF 26,400 LWT SHIPMENTS, AN AVERAGE OF 694 TRUCK SHIPMENTS PER YEAR, OR ABOUT 2 TRUCK SHIPMENTS PER DAY, OVER 38 YEARS. THERE WOULD ALSO BE 14,100 RAIL SHIPMENTS, AN AVERAGE OF 371 RAIL SHIPMENTS PER YEAR.

THE AGENCY'S ANALYSIS CONCLUDED THAT DOE'S MOSTLY RAIL SCENARIO IS NOT CREDIBLE. IF DOE IS ABLE TO CONSTRUCT AND OPERATE A NEW RAIL SPUR TO YUCCA MOUNTAIN, THE AGENCY BELIEVES THAT THE MOST PROBABLE MODAL MIX WOULD BE 26,400 TRUCK SHIPMENTS AND 14,100 RAIL SHIPMENTS. IF DOE IS NOT ABLE TO CONSTRUCT AND OPERATE A NEW RAIL SPUR TO YUCCA MOUNTAIN, THE AGENCY BELIEVES THAT THE MOST PROBABLE MODAL MIX WOULD 96,000 TRUCK SHIPMENTS.

CONCLUSIONS

THE NEVADA AGENCY FOR NUCLEAR PROJECTS HAS STUDIED DOE'S POTENTIAL HIGHWAY AND RAIL ROUTES FOR SHIPPING SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE TO A PROPOSED REPOSITORY AT YUCCA MOUNTAIN. ALL OF THE DOE ROUTES STUDIED BY THE AGENCY HAVE MAJOR PROBLEMS AND DRAWBACKS. THE AGENCY BELIEVES THAT THERE IS NO TECHNICALLY DEFENSIBLE BASIS FOR SUPPORTING ANY POTENTIAL HIGHWAY OR RAIL ROUTE AT THE PRESENT TIME.

THANK YOU FOR THE OPPORTUNITY TO ADDRESS THE COMMITTEE. I WOULD BE PLEASED TO ENTERTAIN ANY QUESTION YOU MAY HAVE.