(1) Title of the Report
The title of the report should be change to "Nevada Test Site Intermodal Transportation and Routing Feasibility Study." Also, the term "feasibility study" should be used throughout the document and the schedule when referring to the effort.
(2) Introduction (page 1)
The "Background" section of the report (Background and Purpose) should clearly describe evolution of the effort into a feasibility study, not a demonstration project. In addition, the "Purpose" statement should be re-written to reflect that the purpose of this effort is to evaluate the feasibility of using intermodal (rail-truck) transportation, in combination with designated highway routes from the intermodal facility to the Nevada Test Site (NTS), as a means of reducing transportation risks by avoiding the heavily populated and extremely congested Las Vegas Valley. The study will lay the groundwork for a programmatic environmental assessment (EA) that can serve as a decision document for a "proposed action" to require all low-level radioactive waste destined for NTS to be shipped via the identified highway route and, if applicable, the selected intermodal facility.
There should be no misunderstanding that this effort is a demonstration project for Fernald-generated waste. The study can most productively be framed as the first step in the overall process that will lead to a DOE decision about waste shipments to NTS from all DOE generator sites. The incorporation of a commitment in the Record of Decision for the Waste Management Programmatic EIS (which is due out in December, 1997) to address, on the basis of equity, Nevada concerns about ongoing and increasing shipments of radioactive materials through the Las Vegas Valley is another important step in this process, which should culminate in the issuance of a programmatic EA selection of a preferred alternative.
(3) Transportation Policy (page 2)
The sentences indicating that the truck route associated with the Caliente Transfer Point is an exception to the compliance with USDOT regulations should be eliminated. There are no USDOT regulations that prohibit low-level waste to be transported by the proposed Caliente route. In fact, the Caliente truck route may well be shown to be a lower risk route because it avoids heavily populated areas and thereby lowers the risk of routine and accident-related exposures.
(4) Community Acceptance Section (Pages 23 - 25)
The report should be careful to characterize the "community acceptance" section as a key informant study, not as a scientific study of community attitudes and perceptions. In framing conclusions for this section of the report, care must be taken not to represent findings as percentages that somehow reflect a level of overall acceptance or rejection. Saying that "sixty percent of the participants objected ..." or that "the remaining forty percent expressed either support for or tolerance of ..." is meaningless because the sample sizes and the way they were selected don't allow for such generalizing. It's better to stick simply to what the key informants said.
(5) The Attached Map
Hoover Dam should be specifically identified on the map provided with the report is, as proposed, the existing truck routes are to be added.
The schedule should be revised to remove references to an "intermodal demonstration project" and replace them with "feasibility study." The schedule should also be made consistent with the purpose of the study (see above).
The October, 1997 milestone, "Determine DOE-Fernald's level of participation...", should be revised to read, "Determine levels of participation for DOE generator sites in the feasibility study and EA."
The reference to issuing a Finding of No Significant Impact should be replaced by reference to adopting a preferred alternative for an intermodal transfer facility and for a designated highway route from the facility to NTS.