Thursday, May 31, 2001
Jennifer O. Viereck, Southeast Area Citizens Advisory Committee to the Inyo County CA Board of Supervisors, Longstreet Casino, Amargosa, NV
First of all, we are extremely appreciative of the enormous volume of research and work that has gone into the further evolution of the repository design since the release of the first Draft EIS in 1999. It seems clear that the DOE has attempted to be responsive to some of the criticisms of that original document. However, in a first reading of the document, several things come immediately to mind:
1. If the design is still so totally in a state of fluctuation, or "evolution", why are we being asked to respond to it, and why is the EIS process moving forward? There are not clear definitions of the design put forward for the Proposed Action, nor are their clear alternatives for comparison. There are a number of variables and parameters that can be combined in different ways kind of like a soup recipe, all still in a very exploratory stage, but no clear conclusions for us to evaluate. This report and this process is completely premature. We don't believe that this premature and incomplete approach to the EIS process is even legal, let alone ethical or responsible to the taxpayers or residents of this region.
2. The time period allowed for hearings and responses to this Supplement, with its enormous but rather sketchily outlined new scheme, 45 days, is completely inadequate. We are not radiation professionals-we are juggling jobs and families, in addition to trying to review this technical material that has tremendous implications to our lives in the future. Since the Radiation Regulations for the Proposed Repository have not been decided, therefore delaying indefinitely the final EIS report and the Site Recommendation process, there seems to be no logical reason for this rushed process. In addition, many people should have the right to review and comment on these broad changes to a huge national policy.
3. This Supplement does not take into account a number of serious discrepancies in the original document that have been pointed out about this region, such as population and employment figures in Nye county. Therefore, how can the dose calculations be accurate?
4. This supplement spells out, in extremely outline form, a number of entirely new facilities and waste handling processes that have enormous implications: a cooling pool, an above ground storage facility that would operate for up to 50 years, mixing and repackaging waste, etc.
5. If storing waste for the next 50 years is now part of the Yucca Mountain plan, why is it not being stored on site, thus eliminating transportation dangers to the public and to residents of this area, while the DOE figures out a truly safe solution? Is exposing our region to this incomplete plan merely being done to avoid litigation from nuclear utility companies?
6. The margin for human error, in record keeping alone, seems enormous. Potentially deadly problems that have happened at nuclear reactor sites already, such as cranes getting jammed while lifting rods out of pools, lids being dropped or gases threatening explosion, would be greatly magnified. The analysis of the potential impacts of these new facilities is very incomplete. The accident scenario for the Waste Handling Facility doesn't appear to include the storage pool or the rods that would be in it. It seems highly unlikely that this above ground facility could even be licensed by the NRC independently, if it were held to the same criteria as other sites under consideration.
7. The only thing that does seem completely clear to us from this document is that it is completely impossible for this project to meet its original mission, "to isolate high-level nuclear waste from the biosphere". On page S-7, it states that the mean annual dose will continue to rise after the arbitrary 10,000 year licensing period, that the peak dosage could range from 120 millirems to 260 millirems, right up the road at the freeway junction, some 550,000 years from now. Has any other federal project, let alone one that is currently estimated to cost $56 billion dollars, ever guaranteed its own failure, right from the start?
8. Lastly, I would ask the DOE to take into account a recent study by the US Geological Survey about storm drainage in our area. Apparently the already radioactive effluent from the Nevada Test Site, and potentially contaminated effluent from the Yucca Mountain area, runs directly into our Amargosa River, impacting Death Valley Junction, Shoshone, Tecopa, the Timbisha Shoshone Tribe, and the 1.4 million visitors each year to Death Valley National Park. These above ground nuclear storage and handling facilities would directly impact surface water, unlike the original deep repository design. We are extremely concerned about much speedier contamination of our watershed than previously thought.
Thank you for considering our comments at this time.
--Jennifer Olaranna Viereck