Readers Note: In July, 1997, the U.S. Department of Energy's Office of Civilian Radioactive Waste Management (OCRWM) requested stakeholder comments on the OCRWM Strategic Plan, which was being prepared as an element of the overall Department Strategic Plan. The Nevada Agency for Nuclear Projects reviewed the draft OCRWM Plan and found that several of the proposed strategies and success measures were not only inappropriate, but they also revealed a disturbing bias regarding DOE's approach to characterizing the Yucca Mountain candidate repository site.



Capitol Complex
Carson City, Nevada 89710
Telephone: (702) 687-3744
Fax: (702) 687-5277
Executive Director

July 30, 1997

Charles Teclaw, RW-54
Office of Civilian Radioactive Waste Management
U.S. Department of Energy
1000 Independence Avenue
Washington, DC 20585

Dear Mr. Teclaw:

In response to Lake Barrett’s letter of July 3, 1997, I am providing the following State of Nevada comments on OCRWM’s section of DOE’s draft Strategic Plan:

Page 23 - Objective 3, Strategy 1

The second success measure for Strategy 1 (Amount of competitively awarded fixed price contracts including privatization contracts) will not necessarily indicate attainment of the objective to “reduce life-cycle costs of environmental cleanup.” Simply having a large number of competitively awarded contracts does not mean that costs are being reduced or that sites are being expeditiously cleaned up. The recent disclosures about the problems with the fixed price cleanup contract for Pit 9 at INEEL is an example of a privatized contract that certainly did not result in lower costs. A better measure would be some form of evaluation done for each contract with a cost-to-cleanup ratio showing how well or poorly the contract reduced cleanup costs.

Page 24 - Objective 5, Strategy 1

There appears to be a serious disconnect in the logic governing "success measures” for Objective 5, Strategy 1 - “Complete the scientific and technical analyses of the Yucca Mountain site, and if it is determined to be suitable for a geologic repository, obtain a license from the Nuclear Regulatory Commission.” The third and fourth “success measures” are inappropriate in that they presuppose that Yucca Mountain will be found suitable and that DOE will, in fact, be in the position to recommend the site to the President in 2001 and to submit a license application to NRC in 2002.

Success, in the context of this objective, could also be attained by determining that Yucca Mountain is not suitable - an equally possible outcome of site characterization - thereby saving the nation billions in trying to make an inappropriate site work. Such an outcome would also save the country from making a mistake of major proportions that would be passed along to future generation, who would have to deal with it.

If DOE’s plan must include success measures for the eventuality that Yucca Mountain is found suitable, it must also include measures for the possibility that the site is not suitable and will need to be abandoned. Measures for the later possibility might include:

• Advise Congress of DOE’s determination that the site is not suitable for development as a repository, pursuant to the provisions of the Nuclear Waste Policy Act, in 2001;

• Recommend alternative courses of action to the President and Congress, including at-reactor dry storage alternatives, that will help define new national policy for HLW and spent fuel management in 2002.

Page 24 - Objective 5, Strategy 2

If DOE decides to include the maintenance of “a core capability to respond to potential statutory direction that may include transportation of spent nuclear fuel and high-level waste to a designated interim storage facility” as a strategy for meeting Objective 5, the Plan should also contain strategies and success measures for the eventuality that DOE will be required to assist utilities and waste generators in developing at-reactor dry storage capacities in the absence of “statutory direction” and under the circumstance that Yucca Mountain will not be found suitable as a repository location. It is entirely inappropriate to strategically plan for one scenario and ignore the other - and likely more plausible - one.

I hope these comments are helpful to you in preparing the Department’s Strategic Plan. Should you have questions regarding this matter, please do not hesitate to contact me.


Robert R. Loux
Executive Director

cc Local Government and Tribe Representatives

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