The U.S. Department of Energy (DOE) plans to begin accepting transuranic waste from DOE weapons' production facilities around the country in May, 1998. These wastes, which are comprised largely of tools, gloves, protective clothing, and other materials contaminated with plutonium as a result of bomb making activities, would be transported from other DOE facilities to the Waste Isolation Pilot Plant (WIPP) in Carlsbad, New Mexico where they will be interred several thousand feet below ground in a large bedded salt formation. The National TRU Waste Management Plan is the DOE document that will provide the policy framework for all activities associated with the transportation and disposal of transuranic wastes.

The DOE Plan was released in December, 1997. The Nevada Agency for Nuclear Projects provided the following comments through the Western Governors' Association (WGA) WIPP Advisory Task Force. The Agency's comments should be read in the context of the DOE Management Plan, which can be accessed by clicking the highlighted reference above.


February 17, 1998

The Nevada Agency for Nuclear Projects reviewed the December 1997 revision of The National TRU Waste Management Plan provided to the State of Nevada by the Western Governors' Association and offered the following comments:

(1) The map showing WIPP shipping routes on page 2 reflects the use of US 93, NV 127, CA 373, I-15, and I-40 to move TRU waste from NTS to Carlsbad. As we understand it, this route has not yet been formally accepted by the California Highway Patrol (CHP). The map should contain a footnote explaining that the NTS route is a proposed route only and could be subject to change based on any subsequent objections from California. The implications here are significant, since if the proposed route cannot be used for any reason, a new route would have to be selected and agreed upon by all parties.

(2) The statement on page 12 (second bullet) that Athe shipping corridors from the Lawrence Livermore National Laboratory and the Nevada Test Site will open in 1999 to ship all stored waste, after which time the corridors will be closed@ is wrong on two counts. First, there is no way that the route identified from NTS through California can be Aopened@ by 1999 if DOE is to meet its commitment to prepare the states of Nevada, California, and Arizona at least 3 years prior to shipment. Nevada expects to be treated in the same manner and provided the same level of preparation as the initial WIPP shipment states. We will not support and will actively oppose shipments beginning in 1999 given the current state of preparedness and lack of resources for training, emergency response, etc.

Second, the statement on page 12 is in conflict with the shipping schedule contained in the tables and charts on pages 26 -28. DOE/Carlsbab (i.e. Ralph Smith) committed, in the meeting with CHP and Nevada representatives held in Sacramento last year, that TRU shipments from NTS would be concentrated so as to be completed within a six month period, after which the route would be Aclosed@. The tables and charts on pages 26 - 28 reflect a 4 year shipping schedule. It is our understanding that California=s tentative willingness to go along with the proposed route is based, in part, on DOE=s commitment to the six month shipping schedule and time of year constraints, among other things.

The plan must be revised to reflect, at a minimum, (1) a beginning shipping date for NTS shipments that reflects the 3 year preparation time requires and (2) a shipping schedule for TRU waste from NTS that reflects the Sacramento meeting commitment to move waste within a six month period.

(3) The section on ARisk Reduction Performance@ (3.2.2.) is misleading and inaccurate. The statement on page 14 that A... the risk, in terms of populations living within the proximity of stored TRU waste inventories, is ultimately reduced by removing waste from the accessible environment and disposing of it in the WIPP@ ignores the fact that risk is being transferred from populations around existing facilities to workers handling prior to, during and after shipment and to populations located along transportation routes and in proximity to the WIPP facility in New Mexico. This is especially true with respect to remote-handled TRU waste, with its higher degree of radiation risk. It is disingenuous to make a case for risk reduction at existing storage sites without addressing the added risks that will be imposed on other populations. If DOE wishes to make the risk reduction argument in the Plan, it must show that the risks of leaving the waste where it is are greater than packaging and shipping it to WIPP and then handling and disposing of it at the WIPP facility.

(4) Table 3-2 on page 17 must be revised to reflect correct NTS shipping dates (see comment number 2 above).

(5) The section on page 22 titled APrivatizing Waste Management Operations@ should clearly state that, in expanding its use of private contractors to implement various aspects of the TRU waste management system, DOE will not abdicate its responsibilities to states and Indian Tribes or attempt to delegate those responsibilities inappropriately. For example, DOE has committed to a very detailed process by which routes for shipments are selected; states, tribes, and communities are prepared; and shipments are ultimately carried out. In many cases, these commitments involve going significantly beyond what is minimally required and have cost implications. When privatizing operations, DOE must hold private contractors to commitments made to states and tribes, even when those commitments mean increased costs for the private contractors.

(6) The site-specific infrastructure and regulatory compliance section for the Nevada Test Site (5.2.7) indicates that all TRU waste will be shipped from NTS by the end of 2003. We believe it is possible for DOE to meet that deadline, but not by using through the schedule listed elsewhere in the Plan (see comment number 2 above).

(7) The statement in the first paragraph on page 55 (Conclusion) that AAchieving the performance-based goals defined in this plan will result in significant reduction of risk ...@ needs to be revised for the reasons stated in comment # 3 above. There is no basis for stating that shipping waste to WIPP results in an overall reduction of risk.

(8) The Plan should either adopt outright or incorporate by reference the WGA/WIPP Program Implementation Guide (PIG) as the basis for cooperating with affected states and tribes in implementing the transportation program for TRU waste. The Plan talks about Ainteracting, as appropriate, with states, tribes and other stakeholders,@ but it does not formally endorse the very specific and detailed procedures set forth in the PIG. We are concerned that, if the PIG is not provided some official status in DOE=s National TRU Waste Management Plan, DOE will be free to disregard at will the commitments the PIG represents. The PIG and the process that led to it should also be referenced and discussed in section 4.1 (Programmatic Initiatives) of the DOE Plan.

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