The Nuclear Waste Policy Act of 1982 created a program designed for the management and disposal of high-level nuclear waste and spent nuclear fuel. In 1987, Congress amended the act leaving Yucca Mountain as the sole area to study for the development of a nuclear waste repository. If recommended by the Secretary of Energy, nominated by the President to the Congress and authorized for construction and operation by the Congress, the Yucca Mountain repository system will have been unilaterally imposed on the residents of Nevada along with its attendant concentration of risk. While arguably necessary, the program has long since lost any concept of fairness or equity with respect to the residents of Nevada. All other states and the U.S. government, who have benefited from the creation of this waste, will have all associated risk irrevocably transferred to the State of Nevada and its residents. In this regard, the Yucca Mountain Repository program represents a unique and unprecedented unilateral transfer of risk.
Within Nevada, the necessity to protect the State’s gaming-based tourist economy will result in shipments of spent nuclear fuel and other high-level radioactive waste moving through rural locations such as White Pine County. Very simply, the largest concentration of long-lived extraordinarily dangerous high-level nuclear waste in recorded history will be transported through rural Nevada and stored in perpetuity at Yucca Mountain, presuming the site is found suitable.
The Yucca Mountain repository system represents an unwanted industrial activity. The allocation of Nevada’s natural, social, fiscal and economic resources required to support the location and operation of the repository system represents an opportunity cost as these same resources will be unavailable for allocation in support of other desired industrial activities. As a consequence, White Pine County views any repository system related impact, regardless of scale, to require mitigation. There are unique local conditions and resultant impacts specific to White Pine County, Nevada, which require full consideration as an integral part of any decision to recommend Yucca Mountain as a safe and enduring repository.
This report has been developed to help White Pine County understand the full range of impacts and risks that may be imposed upon it. The goal is to identify mitigation and compensation measures that will reduce the burden if White Pine County is selected as part of a transport route to bring the high-level nuclear waste to Yucca Mountain.
This report has been submitted directly to the Secretary of Energy and White Pine County expects the Secretary to consider the findings in formulating a recommendation to the President. In addition, White Pine County expects the Secretary of Energy to submit this report, pursuant to Section 114(a)(1)(G) of the Act, to the President.
Since 1992, when White Pine County received status of Affected Unit of Local Government, the County's Nuclear Waste Project Office has commissioned a series of independent studies from respected researchers at technical consulting firms as well as academic institutions. The independent studies were designed to inform the residents of White Pine County on the range of impacts that might be expected if the State of Nevada designates a legal-weight truck route through White Pine County. NWPO staff, White Pine County Nuclear Waste Advisory Board members and the White Pine County Board of Commissioners have supervised the conduct of several studies documenting repository system implications for White Pine County. Topics addressed within these studies include economic/demographic baseline conditions, emergency response, economic/demographic projections, transportation risk assessment, and environmental impacts, among others. These studies, as well as additional relevant reports on risk, stigma, and transport risks are the basis for this report.
The findings indicate that the impacts for White Pine County are highest in the areas of emergency management, highway accident risk, radiation exposure risk, and from stigma that may reduce the desirability of White Pine County as a place to live and as a destination for tourists. The identified impacts are summarized in ES-Table 1: Summary of Impacts to White Pine County from the Yucca Mountain Repository System. This assessment considered impacts from all phases of the repository, including site characterization, transportation system construction, transportation system operation, repository construction, and repository operation.
In considering mitigation measures to reduce the impacts of the Yucca Mountain Repository System on White Pine County, Council for Environmental Quality (CEQ) management techniques were utilized as the framework. These are defined as follows:
• Avoiding the impact by not taking certain action or parts of an action.
• Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
• Rectifying the impact by repairing, rehabilitating, or restoring the affected environment.
• Reducing or eliminating the impact over time by preservation and maintenance during the lifetime of the action.
• Compensation for the impact by replacing or providing substitute resources or environments.
Table ES-2 summarizes the options to mitigate impacts on White Pine County from the Yucca Mountain Repository System. The purpose is to highlight the range of techniques that would serve, where possible, to mitigate impacts in White Pine County if the State of Nevada designates a legal-weight truck route through the County and the City of Ely. Mitigation would require specific action on the part of DOE and/or DOE contractors in order to avoid, minimize, or reduce impacts and risks.
The range of impacts that may be imposed on White Pine County are not all amenable to monetary compensation. However, monetary compensation is necessary for impacts that cannot be avoided, minimized, rectified, reduced or eliminated. Table ES-3: Summary of Estimated Mitigation Costs for White Pine County, outlines the estimated costs of mitigation where estimation of those costs is possible.
Within the Draft Environmental Impact Statement (DEIS) for the Yucca Mountain Repository, the DOE has provided only cursory analysis of the risks inherent in transportation of quantities of highly radioactive spent nuclear reactor fuel and high-level waste on an unprecedented nationwide scale over a very long period of time. The limited transportation analysis performed for the DEIS was often based on grossly outdated or simplified demographic and physical data, even though up to date information of this type was readily available. A rationale for this approach is very difficult to understand, but has the effect of trivializing or grossly underestimating the real risks associated with transportation of high-level waste.
Further, the DOE has, to date, completely ignored socioeconomic and stigma based effects of the repository program on the economy and society of the residents of White Pine County. Many people living in White Pine County have direct personal experience with the societal effects of radiological exposure as "downwinders" from Nevada Test Site atmospheric testing of nuclear weapons. To represent through silence that there are no socioeconomic or societal effects from a program that has the potential to subject citizens and the environment to exposure from radioactive waste is difficult for current residents to accept.
The result is that the DOE has so far represented to the Congress, the Administration, the State of Nevada, and affected units of local government that the overall risk implicit in the transportation to and storage in perpetuity of high-level nuclear waste at Yucca Mountain represents minimal and statistically acceptable risk and is completely manageable. We believe this conclusion is disingenuous and based on flawed, incomplete analysis and/or simply failure to consider certain impacts of the program. Consequently, we strongly disagree with the DOE’s findings thus far.
Rather, we feel that there is significant risk of unanticipated consequences inherent in the Yucca Mountain Repository Program. When viewed in totality, the risks in an overall sense appear unmitigable through any reasonable means. It will be very difficult for the nation to transfer its nuclear waste risk to Nevada without diminishing the health, safety, and welfare of the states' residents and visitors. It is our view that these impacts can only be fully mitigated by not going forward with the Yucca Mountain Repository Program. That is our fundamental conclusion.
We reluctantly acknowledge, however, based on the historical lack of fairness, inequity, and incomplete science that has regrettably characterized the Yucca Mountain Program over the last decade, that the program may well go ahead. Should this be the case, we believe that it would be both irresponsible and ethically wrong for the Administration and Congress to fail to provide, to the extent practicable, mitigation of impacts and to the residents of Nevada, an equitable share of the national benefit that proponents of the project claim will result.
As indicated in Section 3.3 (Impact Scenarios), transportation incident/accident related impacts and impacts resulting from the presence of the Yucca Mountain Repository are both wide-reaching and potentially devastating to the residents of White Pine County, its economy and society.
They are well beyond anything identified by the DOE in its Yucca Mountain DEIS. Regrettably, we will not have sufficient opportunity under the DOE’s current schedule to review the final EIS, prior to issuance of this report to determine if their final assessment of impacts approaches those we have identified. Further, we will not know with certainty until a much later time frame as to whether spent nuclear fuel and high level waste destined for the Yucca Mountain Repository will in actuality be transported through White Pine County on legal weight trucks.
Our conclusion that spent nuclear fuel and high-level waste should not be transported through White Pine County on legal weight trucks due to the potential for catastrophic and largely unmitigable impact remains firm and resolute. We also view the presence of the Yucca Mountain Repository as having substantial negative impact on White Pine County.
Should circumstances and the will of the Administration and the Congress result in imposition of these potential impacts on the residents of White Pine County, we feel that all means available to mitigate impacts of the Yucca Mountain Repository Program should be provided without reservation to White Pine County. In addition, we recommend that Nevadans be provided monetary and other benefits equivalent to an equitable share of the benefit provided by the repository system to the Nation.