White Pine County Comments to Draft Environmental Impact Statement  

 

January 26, 2000

Wendy R. Dixon, EIS Project Manager

Yucca Mountain Site Characterization Office

Office of Civilian Radioactive Waste Management

U.S. Department of Energy

P.O. Box 30307, Mail Stop 010

North Las Vegas, Nevada 89036-0307

Dear Ms. Dixon:

Consistent with requirements of the National Environmental Policy Act (NEPA) and consistent with the fiduciary responsibility vested to it through designation by the Secretary of Energy as an "affected unit of local government" pursuant to the Nuclear Waste Policy Act (NWPA) the Board of White Pine County Commissioners are submitting these comments to the Draft Environmental Impact Statement (DEIS) for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada.

White Pine County is submitting these comments with full expectation that they will serve to enable the Department of Energy (DOE) to prepare a Final Environmental Impact Statement (FEIS) which meets the statutory requirements for a "legally sufficient" document which can be used by the Secretary of Energy, the Nuclear Regulatory Commission (NRC), the President of the United States, and the Congress in making major federal decisions regarding the transportation and disposal of spent nuclear fuel and other high-level radioactive waste. Failure by the DOE to adequately address White Pine County's comments in preparing the FEIS may render the document legally insufficient to support major federal decisions.

Please feel free to contact me should you have any questions regarding these comments.

Sincerely,

 

Brent Eldridge

Chairman

cc:    Nuclear Regulatory Commission

        U.S. Environmental Protection Agency

        Governor Kenny Guinn

        Members, Nevada Congressional Delegation

 

 

 

 

Comments to Draft Environmental Impact Statement for a Geologic Repository

for the Disposal of Spent Nuclear Fuel and High-Level

Radioactive Waste at Yucca Mountain, Nye County, Nevada

 

 

Submitted To:

Wendy R. Dixon, EIS Project Manager

Yucca Mountain Site Characterization Office

Office of Civilian Radioactive Waste Management

U.S. Department of Energy

P.O. Box 30307, Mail Stop 010

North Las Vegas, Nevada 89036-0307

 

Submitted By:

Board of White Pine County Commissioners

953 Campton Street

Ely, Nevada 89301

 

January 26, 2000

 

These comments are divided into those concerning process (ie. preparation of the FEIS), those of a general nature (not addressing a specific section of text in the DEIS) and those of a specific nature (addressing a specific section of text, particular table, etc.). General comments focus upon fundamental deficiencies in the DEIS. Substantive changes to the DEIS are required to address the general comments provided by White Pine County. To the extent that such changes introduce substantial new information or uncover previously undisclosed significant impacts, White Pine County would encourage DOE to issue a revised DEIS for further public review and comment.

Process Comments

In preparing the FEIS, 40 CFR 1502.9(b) requires DOE to respond to all comments received and to discuss any opposing views on issues raised. White Pine County understands that DOE has the option to group comments together and to provide generic responses to input received. However, given the complexity of the repository project and the geopolitical brevity and differences of the affected region, the County urges DOE to provide individual responses to all comments it receives. White Pine County deserves to know DOE's specific response to each comment and how, if at all, said comment resulted in a revision of the DEIS. The County requests that DOE prepare a comment response document and that said document be made available prior to or concurrent with release of the FEIS.

Prior to release of the FEIS, DOE is encouraged to meet with affected units of local government to discuss how the Department intends to revise the DEIS in responding to local government comments. Such a meeting will insure that DOE fully understands the local government comments and that the proposed response or revision to the DEIS satisfies the issue of concern

DOE is encouraged to identify and make commitments within the FEIS to reasonable measures to mitigate significant impacts. The subsequent Record of Decision to be issued by DOE should also identify mitigation measures to be implemented. DOE is discouraged from preparing a separate and stand-alone mitigation plan. Such a document does not fulfill the requirements of and indeed is outside the NEPA legal framework governing the minimization of the effects of major federal decisions.

The DEIS does not reveal the process DOE plans to use in selecting a preferred rail and/or heavy-haul corridors. The baseline information provided in Chapter 3, and the impact analysis provided in Chapter 6 and Appendix J, are particularly deficient regarding impacts on highly populated areas-, engineering feasibility; construction costs, and cost uncertainties; potential for voluntary acquisition of private lands; impacts on Native American lands and cultural resources; and economic development costs and opportunities, including risk-induced socioeconomic impacts. The FEIS must include a specific framework for identifying preferred transportation modes and routes.

General Comments

In its current form, the DEIS does not contain sufficient information to fully assess all reasonable alternatives. For example, the DEIS does not consider specific impacts associated with legal-weight shipments of spent nuclear fuel along U.S. Hwy 93, U.S. Hwy 6, and State Route 318 through White Pine County. Given that this route has been identified by the Nevada Department of Transportation as one of two candidates for designation by the Governor as an alternate to Interstate 15 and U.S. Hwy 95 through Las Vegas and given that the State of Nevada has already encouraged DOE to use the Hwy 93, Hwy 6, SR 318 route to ship LLW and thereby avoid the Las Vegas Valley, it is a clearly reasonable alternative for which specific analysis in the DEIS is lacking.

The Draft EIS does not analyze impacts associated with specific nuclear waste transportation routes, even though it is intended that it will be used at some time in the future to select transportation modes and routes from 75 individual waste sites to Yucca Mountain. Residents along potential transportation routes to Yucca Mountain - through 43 states, and within 1/2 mile of more than 50 million people - are most knowledgeable about local hazards, yet their specific knowledge is co-opted by the generic treatment of transportation risk in this Draft EIS. This generic approach also eliminates any substantial analysis of environmental justice, which leads the Draft EIS to conclude, despite dissenting opinion, that there are no environmental justice issues that require analysis.

With respect to eastern Nevada, the DEIS fails to consider the potential impacts of legal weight truck (LWT) shipments of Spent Nuclear Fuel (SNF) and high-level radioactive waste (HLW) through Elko and White Pine Counties. Studies prepared for the Nevada Department of Transportation (NDOT) have identified Alternate US 93 from West Wendover to Lages Station, US 93 from Lages Station to Ely, US 6 from Ely to Tonopah, and US 95 from Tonopah to Yucca Mountain as a possible route for highly radioactive materials shipments. Appendix J of the DEIS identifies this route, the so-called "NDOT B Route," as a potential state-designated alternative route for truck shipments to the repository. DOE used portions of this route for truck shipments of SNF from the Idaho National Engineering and Environmental Laboratory to the Nevada Test Site in the 1980s.

Failure of the DEIS to consider the impacts of legal-weight truck transportation through White Pine County is made worse by Table J-48 which demonstrates that risks of transporting spent fuel and high-level radioactive wastes through the County are significantly greater than the risks for the Base Case (routes allowed by current Department of Transportation regulations for Highway Route-Controlled Quantities of Radioactive Materials). The fact that LLRW is also being transported on a route through White Pine County raises the specter of significant cumulative impacts.

According to the DEIS, there could be about 49,500 to 96,000 LWT shipments to the repository under the mostly truck scenario. Ninety percent or more of these shipments, an average of 5 to 10 trucks per day, could travel the NDOT B Route through West Wendover, McGill, and Ely.

The Draft document fails to consider unique local conditions along the NDOT B Route that could result in significantly higher routine radiological exposures than those calculated using by DOE using the RADTRAN 4 computer model. For example, individuals who reside, work, or attend school at certain locations within 6 to 40 meters (20 to 130 feet) of a nuclear waste highway route could receive exposures in excess of the average annual background radiation dose. DOE has failed to investigate whether such conditions exist near school zones and pedestrian crossings, left-turn lanes and traffic signals, congested intersections, and uphill grades in West Wendover, McGill, and Ely.

The DEIS also fails to consider unique local conditions along the potential truck route that could cause unacceptable safety and security risks for truck shipments using General Atomics GA4/9 casks. Primarily a rural two-lane highway with numerous steep grades and sharp curves, the route traverses high mountain passes subject to severe winter storms. Long segments (up to 60 miles) have no safe parking areas, few refueling facilities, and limited local emergency response capabilities. The Draft report assumes that almost all truck shipments will be made in the new GA-4/9 casks. The weight of the loaded GA-4/9 cask requires that it be used in conjunction with a specially designed trailer, a lower weight, cab-over-engine tractor, and a single fuel tank. DOE has failed to demonstrate that the GA4/9 system is appropriately designed for a decades-long, nationwide shipping campaign to Yucca Mountain.

The Draft EIS fails to consider unique local conditions along the NDOT B Route which may increase the probability of severe accidents, and which could exacerbate the consequences of a severe accident or terrorist attack resulting in a release of radioactive materials. There are numerous mountain passes, such as White Horse Pass, Currant Summit, Black Rock Summit, Sandy Summit, and Warm Springs Pass. Near-route terrain frequently includes drop-offs into deep canyons or river valleys that would make response to an accident or attack, and recovery of the cask, damaged or not, quite difficult. Route proximity to surface water and groundwater resources is a major concern. DOE has failed to address the implications of route-specific conditions for accident prevention, emergency response, and the economic costs of cleanup and recovery.

The DEIS fails to consider unique local conditions along the NDOT B Route which could result in unacceptable adverse socioeconomic impacts. During the past decade, there has been significant demographic and economic growth in and around West Wendover and Ely. Most of the new commercial development, including hotels, casinos, restaurants, and retail sales establishments, has occurred within two miles of the NDOT B Route. The Draft EIS ignores the potential adverse impacts of large numbers of SNF shipments on tourism-based economics located near highway routes to Yucca Mountain. State-of-the-art risk studies sponsored by the State of Nevada researchers have documented the public perception of risks associated with nuclear waste transportation. DOE has failed to address potential adverse impacts on year-round tourism, seasonal tourism, and special-event tourism; the effects of risk perception on property values along shipping routes; and risk-related impacts on business location and expansion decisions.

The analysis of socioeconomic impacts in this Draft EIS does not include the impacts associated with perceived risk and stigma. It is well documented that negative reaction to nuclear waste ranks highest among reactions to risks within the U.S. population. In response to such perceptions, people behave in ways that have direct and measurable economic consequences (i.e. avoidance of places and products associated with nuclear imagery or stigma). The DEIS ignores this finding and does not consider the economic consequences of such stigma on tourist destinations and agricultural products available in White Pine County.

For White Pine County, a transportation accident just before the peak summer tourist travel season which was characterized by a great deal of media amplification of risks could result in stigmatization of the area and a significant and prolonged decrease in tourist visitation to the County. Information compiled by the Nevada Division of State Parks and the National Park Service indicate that combined peak season (July) visitation to Cave Lake State Park and Great Basin National Park has approached 50,000 visitor days in recent years. With the population of the western states expected to grow by tens of millions over the next 25 years, annual tourist visitation to Cave Lake State Park and Great Basin National Park are expected to also increase annually.

White Pine County has recently adopted a plan for managing the abundant and high-quality surface and ground water resources which characterize the area. Said plan envisions significant portions of these waters being put to beneficial use by way of beverage bottling to meet an ever-growing demand for beverages in the Western United States. The DEIS does not reference the White Pine County Water Resources Management Plan nor the potential for transportation of radioactive wastes through the County to stigmatize area water resources.

With regard to failure of the DEIS to adequately address transportation impacts it is important to note that transportation induced stigma must also be considered within the Final EIS. Research sponsored by the Board of Lincoln County Commissioners has demonstrated that transportation induced stigma can result in significant economic and fiscal impacts along transportation corridors. In the event of an accident involving transportation of spent nuclear fuel in the weeks preceding peak tourist travel to and/through White Pine County, local businesses may be impacted and tax revenues lost to White Pine County and the City of Ely. It could take several weeks to many months for the area to recover from negative perceptions about safe travel in the County.

Based upon analogous cases (ie. visitation impacts of the accident at Three Mile Island), the DEIS must consider the possible economic and fiscal impacts to White Pine County of a transportation incident/accident which results in stigma induced reductions in tourist visitation to the County. Measures to mitigate such a downturn in tourism must be presented in the EIS. For example, DOE should commit to develop and fund a tourism marketing plan which could be immediately implemented in the event of a transportation accident in the County. Using an IMPLAN-based economic impact model developed for the County by the University of Nevada, Reno (Center for Economic Development), preliminary estimates of the economic impact of losing 30 percent of visitor days during the month if July could result in direct economic impacts of over $400,000 and total economic impacts in excess of $1,000,000 to the local economy.

The DEIS should estimate the number of expected transportation incidents/accidents which might be expected to occur within White Pine County over the 24 year shipping campaign. This information could be easily derived from U.S. Department of Transportation incident/accident reports prepared for other shipments of spent nuclear fuel and high-level radioactive wastes. There have been incidents and accidents in the past. There will be such occurrences in the future. White Pine County is concerned that any single transportation incident or accident, even assuming no release of radioisotopes to the accessible environment, could be widely covered by the media, with perceived risks amplified and area stigma a result.

The draft EIS fails to consider transportation impacts on specific Native American communities located in proximity to potential spent nuclear fuel and high-level radioactive waste routes. In particular, there is no evaluation of possible impacts to the Duckwater Reservation, which is located in proximity to US 6 and the NDOT B route.

The DEIS does not include a reasonable No Action Alternative. It is unlikely that either of the No Action Alternatives included within the DEIS would ever be considered for implementation. In particular, No Action Alternative Scenario 1 entails radioactive waste to be left at the 77 sites where it is now found, but under institutional control for 10,000 years. Scenario 2 envisions loss of institutional control after 100 years. NRC guidelines discourage licensees from assuming institutional control beyond 100 years. However, it is highly unlikely that waste would be allowed to be stored at generator sites without any form of institutional control. A more reasonable No Action alternative would see waste stored on-site indefinitely with continued institutional controls.

White Pine County is troubled by the DOE's failure in the DEIS to recognize the County and its residents as potentially impacted by on-going and proposed radioactive waste management activities in Nevada. During scoping, White Pine County made a credible case for consideration of the impacts of low probability/high consequence events such as volcanism upon the residents and environment of the County. In addition, our scoping comments clearly demonstrated the potential for shipments of spent nuclear fuel and high-level radioactive waste to be transported by legal-weight truck through White Pine County. Despite the direct risk to resident public health, safety and welfare associated with the Yucca Mountain project, the DEIS does not afford any assessment of impacts to residents and the environment in the County.

This failure to consider impacts in White Pine County appears contradictory to the Secretary of Energy's previous action to designate the County as "affected" pursuant to the Nuclear Waste Policy Act. The Secretary's designation, which is not required but is discretionary, clearly suggests the relationship of ongoing and proposed DOE radioactive waste management activities in Nevada to possible localized impacts in White Pine County. It is inconceivable that the Secretary of Energy would consider White Pine County "affected" yet the DEIS would not consider impacts which might accrue to residents and/or the environment of the County.

The DEIS does not adequately address issues raised and substantiated by White Pine County during the scoping process. A summary of key issues raised by the County which have not been sufficiently addressed within the DEIS follows:

Collectively, failure of the DEIS to address most of the issues raised by White Pine County during scoping renders the document wholly inadequate.

The National Environmental Policy Act (NEPA) requires federal agencies to consider "connected actions." Construction and operation of a repository at Yucca Mountain will result in spent nuclear fuel and high-level radioactive waste being transported through Nevada (and in all likelihood by legal-weight truck in the short-term). The prospect of transportation of spent nuclear fuel and high-level radioactive waste through the Las Vegas Valley will likely trigger a decision by the Governor of Nevada to designate alternative routes. Therefore, the FEIS must consider the impacts of State of Nevada identified alternative routes as a connected action pursuant to NEPA.

A serious omission in the DEIS is the identification and evaluation of alternatives for mitigation of impacts. White Pine County's preliminary review of the DEIS has found no obvious commitments by DOE to mitigate any impacts. The FEIS must include both the identification and evaluation of mitigation alternatives as well as commitments to feasible mitigation measures.

The description of the repository system, including transportation, is too vague to enable assessment of impacts. The degree of ambiguity and uncertainty associated with key assumptions (i.e. whether or not State of Nevada will designate alternate routes) renders the analyses deficient for decision-support. DOE is encouraged to validate assumptions, reduce uncertainty, and remove as much ambiguity as possible in presenting a revised analysis of impacts in the FEIS.

Although the DEIS acknowledges that there could be impacts to Native American cultural sites along rail spur routes or at Yucca Mountain, the draft document completely ignores wider issues and impacts to Native peoples and communities. The draft includes a discussion of the Native American "perspective" on the project, but then proceeds to discount the viewpoint expressed and goes on to conclude that no significant impacts to Native Americans will occur, even though no substantive impact assessment work has been done in any of the Native communities potentially affected by the facility or by transportation routes.

Impacts on American Indian communities within the DEIS are specified in more detail than other communities. There seems to be some bias that the only "Traditional Cultural Properties" considered are those related to American Indian Communities. This is a misconception. Traditional cultural properties could also be related to Pioneer settlements (for example the original Wagon Train route used to settle Preston and Lund or the Keystone and HiLine steam railroad corridor for the Nevada Northern Railroad). There is no assessment of the impacts of the proposed action on cultural tourism. This is a particularly important issue for White Pine County (and other areas like Death Valley National Park) where the economy is currently being re-arranged from traditional extractive industries to tourism.

It is very difficult within the DEIS to evaluate impact on communities in the major zone of influence. One is hard pressed to find any quantification of how many actual legal weight-truck haul loads could be expected through Ely on the US 93 or SR 318 scenario. The table on J-7 might indicate around 1500 shipments from the Idaho National Engineering and Environmental Laboratory 800 shipments from Hanford that might use a route through Ely as an alternate to Interstate routes, spread over a 20-year period (Table J-4). It would be useful if there was analysis of some key points like Ely (apparently a relatively low impact area with about 350 shipments of high-level radioactive waste a year, Table J-4) as opposed to perhaps high impact Mesquite with perhaps an average of 1700 shipments a year of commercial spent nuclear fuel (Figure J-10). The FEIS should identify the impacts of this increase of traffic on tourism trade. The DEIS should describe time of day, day of week and seasonal characteristics of shipping campaigns. Would there be an effort for shipments to occur during low season traffic times? The FEIS should consider the changing demographics of "snow-birds". The attitudes of snowbirds toward radioactive waste shipments should be considered within the FEIS. Would shipments be scheduled to occur during low traffic or high traffic hours, being moved at night or during the day? The effect of transport corridors be designated as "heavy-haul nuclear free" as a mitigating measure in order to alleviate concerns of motorists who wanted to avoid worst case scenario nuclear accidents should be considered within the FEIS? The extent to which such a measure might also reduce the possibility of exposure if there was a highway accident causing a loss of containment should be addressed within the FEIS.

The prevailing impression (including within the DEIS) is that significant archeological properties can be bought. Yet the cost of conducting data recovery operations is not specified within the DEIS. It appears that a majority of the significant archeological sites at the Yucca Mountain site have already been treated through data recovery. What have been the costs of this treatment? How do these costs at the sites at Yucca Mountain compare to data recovery costs at locations where highway or rail improvements may be made? The kinds of sites at Yucca Mountain may be much less expensive to conduct data recovery operations than sites in valley floors or riparian zones that tend to be more complex and therefore expensive to conduct data recovery operations. What kind of sites might be of such high value that data recovery should not be undertaken, but rather sites should be avoided by through re-routing and preserved in place. This is a particularly relevant question for a situation like Five Finger Ridge along I-70 between Richfield and Cove Fort in Utah. This site should have (and could have) been avoided if there had not been a mentality at work in the early 1980's that all archeological sites could be "mitigated" by data recovery. Why has the DEIS not considered off-site mitigation along potential "tourist corridors" that would be alternative routes to avoid heavy haul nuclear waste shipments?

There is reference to a DOE, Advisory Council on Historic Preservation agreement in each DEIS section on cultural resources. This agreement is now several years old. There are new standards for these agreements that emphasize public involvement and alternatives to data recovery as mitigation measures. Will this agreement be modified to deal with the very different issues in treating cultural properties on linear corridors rather than in large area blocks? Will there be more emphasis on public involvement and public availability of popular and research reports emanating from mitigation?

Can the experience of transport of low-level and transuranic nuclear waste and impacts (ie. Waste Isolation Pilot Plant (WIPP) and shipments to Nevada Test Site) be used as a model for the Yucca Mountain repository? To what extent was WIPP Program Implementation Guide for transportation considered as a model for Yucca Mountain regarding mitigation within the DEIS? Was the experiences of these other shipping campaigns used as examples to assess community impacts and transport accident rates within the DEIS?

A variety of discrepancies within the DEIS text and tables and inconsistencies in data presented in the document exist. Several of the risk computations use assumptions that do not appear to be consistent with known references, and reasonable expectations. Examples of these problems with the DEIS are included within the specific comments which follow. Several of the "worst case scenarios" do not appear to be "worst case" for White Pine County. Using known intersections, traffic conditions, established weather patterns and road usage, County reviewers were able to develop several worst case scenarios that meet or easily exceed the ones listed in the DEIS. Examples of possible "worst case" scenarios which should be considered within the FEIS as a means to bound impact assessment and to identify reasonable mitigation measures include:

Accident Scenarios

Non –Accident Scenarios

Repository Pre-closure/Post-closure Scenarios

DOE is also encouraged to give serious consideration to the scenario presented by Ms. Elizabeth Risden, a White Pine County resident, at the October 19, 1999 DEIS hearing in Ely.

Assumptions made in the DEIS, especially as such relate to cask permeability and potential for breach, seem very conservative and perhaps not well thought through. The use of conventional highway traffic data, while convenient may have limited applicability when examining scenarios within White Pine County.

Failure of the DEIS to designate a specific route, or even mode of transportation in advance of evaluation of the environmental impacts, grossly impacts the ability to prepare for and ameliorate the consequences of potential crash, or breach of containment. Here the cart is clearly before the horse. Government agencies, even individuals cannot adequately prepare for an infinity of scenarios. The designation of modes of transportation, the material to be transported (BWR, PWR, Greater that Class C, Weapons Grade Plutonium, Special Performance Assessment-Required LLW, etc), the routes, timing, seasonal and other factors should be ostensibly determined in advance of evaluation of environmental impacts.

Several things were not even considered, or were given extremely low priority in this DEIS, most noticeably the lack of assessment of socioeconomic impacts and public perception in both eventful and uneventful transport. While most considerably a statewide issue and one that will greatly impact Nye and Clark counties, White Pine County, by virtue (or lack thereof) of relative economic poverty could conceivably suffer severe economic hardships. This is especially true in worst case scenarios. The lack of consideration for these issues may stem from the lack of designated routes and modes of transportation. Nonetheless, the DEIS should address these concerns and offer mitigating proposals to offset the deleterious effects.

Understanding that the public's perception of nuclear waste as inherently dangerous rather than potentially dangerous, the DEIS should address in detail the public's concern, the potential for economic downturns, and suggest economic and social compensation for both uneventful transportation and storage scenarios as well as worst case scenarios.

The DEIS conveys preconceived notions regarding the safety and efficacy of transportation of high-level nuclear waste and their subsequent storage at the Yucca Mountain site. Recognizing that transportation of hazardous materials and especially radioactive products has an excellent track record in the United States, and moreover that many great minds have established proven protocols to handling these products, White Pine County recommends that the results of this DEIS be reviewed by an independent technical group to ensure that analyses are appropriate and that all measures to effectively manage risk have been considered. While admittedly a costly measure, because of the nature of the material involved and longevity of the impact, a second study, ordered by the Congress of the United States, by another agency or group, might well be undertaken in an effort to confirm or dispute the findings in this report. At the very least, a group of experts in the various fields associated with this report, not associated with the Department of Energy or even the NRC should be assembled and charged with the task to carefully review this document with the understanding that their comments would be accepted, utilized and indeed exercised even after the February 9, 2000 comment period expired.

White Pine County is concerned that here is no review of potential state-wide impacts, how changes in regional economic trends might impact neighboring counties, or impacts that could occur in counties along proposed transportation routes. It is not possible to suggest specific positive or negative impacts to White Pine County without initial analysis on anticipated state and regional impacts. In addition, the DEIS should include a separate review and analysis of impacts to communities along transportation routes once they have been selected. The FEIS should commit to such an analysis and the related identification of mitigation measures.

All communities with the state could be impacted by changes in the economic picture for the entire state because of the repository. The DEIS provides no assessment of the impacts to counties and cities from losses in state-level economic and fiscal activity. The State of Nevada Nuclear Waste Project Office has demonstrated the potential for statewide tourism related economic and fiscal impacts as a result of nuclear waste being transported throughout the state and stored at Yucca Mountain. State sales and gaming tax revenues could be reduced, and this would impact state services and funds available to counties and cities for local services. It is also possible that the fact that high level nuclear waste is being transported on Nevada highways may influence motor freight routes. Communities like Ely receive a significant economic benefit from the increasing amount of truck traffic over US Highway 93 and State Route 318. If trucking firms elected to use Interstate 15 instead to avoid the routes used for high level nuclear waste, then our communities and the state as a whole would feel an economic impacts. Each of these key issues needs to be addressed in the FEIS.

Positive and negative impacts in neighboring counties including Lincoln, Nye, and Eureka Counties could indirectly impact White Pine County. Moderate increases or decreases in population and economic strength in Eureka, northern Nye, and northern Lincoln Counties could impact White Pine. These areas currently depend, at least in part, on Ely as a commercial and professional center. Decreases in their economies could reduce White Pine County’s economic activity from its neighboring counties. Increases in population and activity could increase the economic activity in White Pine County. If the increases in the neighboring areas were significant enough to support development of new commercial and professional activity, it could decrease the activity now coming to White Pine County. These connected actions or impacts have not been considered within the DEIS.

It is possible that selection of transportation routes through White Pine County could result in socioeconomic impacts for White Pine County. If the presence of trucks hauling high-level nuclear waste in White Pine County required new state and/or federal employees in the area, their households would generate revenue in the community. New private sector ventures could be warranted to provide parking areas or shuttle services between parking and motels. However, the negative impacts of the presence of high-level nuclear waste could include reduced tourist traffic to White Pine County attractions, reduced customers for businesses located along the transportation routes or near the parking areas, reluctance of lenders to finance projects located within the corridor because of potential environmental hazards or increased risk perceived for the area; and regulations governing the use of areas along the transportation route could deter future land use decisions on mining, grazing, or tourism/recreation projects. The identification and analysis of impacts to the local economy in White Pine County and the City of Ely need to be included within the DEIS. Absent such analyses and identification of appropriate measures to mitigate impacts, potential effects will go unmitigated. Such an outcome is inconsistent with the intent of NEPA. The limited discussion regarding Clark, Lincoln, Nye, Eureka, Lander, and Esmeralda Counties does not show the true picture of impacts White Pine County could expect from the development of Yucca Mountain to store high level nuclear waste.

Although White Pine County is a remote rural area, the topography, climate, population concentration, existing transportation systems and economic condition are unique and must be considered in any decision on transportation routing for hazardous materials. The absence of any data in the DEIS concerning this is particularly disconcerting for the County's emergency first responders. Besides transportation issues, it is a fact that White Pine County is downwind of Yucca Mountain and its residents have had health problems from testing conducted at the NTS. County residents would probably prefer the no action alternative where wastes are stored at their current locations. The DEIS should consider baseline health and public perceptions of risk.

Although the DEIS considers possible exposures due to historical shipments as a component of cumulative risk, it does not appear to include collective historical and future doses resulting from weapons testing. There has been historic deposition of radionuclides in White Pine County from DOE weapons testing activities. Residents of the County face the potential for exposure to concentration of radionuclides deposited in the County (ie. while hunting on mountaintops in the area) which when combined with exposures from reasonably foreseeable events, may result in a cumulative dose. The DEIS must consider the cumulative dose to White Pine County residents from historic weapons testing as well as historic and anticipated transportation activities through the County.

Transportation routes identified by the State of Nevada and evaluated in Appendix J go through White Pine County's most populated area and county seat, Ely. Here, ninety percent of the County's population exists within a 15 mile radius of the Ely city center and proposed transportation route. The main highway to the southwest goes five miles uphill along a winding, mountainous two lane route to Murry Summit (which is 7,300 feet high) passing within yards of the main water supply for the city. For six to eight months of many years, U.S. Hwy 6 is often icy and snow covered. It is not unusual for emergency first responders to take an hour to reach an accident site on any major highway because of the distances involved. If any highway is closed there are limited alternatives for routing traffic. The resulting economic impact could be devastating. Fog and snow can and has closed the only airport. The only hospital has limited capabilities. Volunteers are relied upon for fire and EMS resources. The DEIS does not adequately address these issues. The FEIS should include an assessment of unique circumstances impacting upon effective emergency first response in White Pine County.

Studies need to be undertaken to provide accurate assessments for those who are making transportation decisions concerning this area. Resources are limited and often inadequate without adding another demand on them. Money needs to be provided to increase the capabilities to specified levels and it must be provided to maintain those levels. Communications systems, support facilities, shelters, training and equipment, as well as qualified personnel are really inadequate to handle any serious accident. If a decision is made to route radioactive wastes through the county the costs associated with providing proper health and safety response agencies must be considered. There are some problems which money cannot solve. The DEIS then, must consider a combination of mitigation and compensation if risk management through effective emergency first response is to occur.

Before any decision is made concerning routing shipments through White Pine County a thorough assessment needs to be conducted and the results conveyed to those who will make the decision. This information, if not contained within the FEIS, should be a component in a subsequent supplement to the FEIS.

Carrier and shipper responsibilities and emergency response procedures require that response entities have a response team on call 24 hours a day. Will DOE and its carriers require/request 24 hour response capabilities of local first responders? The regulations at 10 CFR, Part 73, govern special safeguards. These regulations specify that transport vehicles carry personal communications devices. The DEIS should evaluate the extent to which such devices will function in rural Nevada and the extent to which rural emergency first responders have compatible communications capabilities. Of particular concern is the extent of communication "dead spots" located in areas of high accident hazard (i.e. canyons). Measures to mitigate communication deficiencies should be identified and evaluated within the DEIS (i.e. repeaters).

The DEIS should recognize that communications would be helpful to situation assessment. Keeping in mind that there is a lot of highway area and distance to travel, emergency first responders would benefit from knowing what was occurring at the incident before these Emergency Response Teams from White Pine County arrive. The FEIS should consider what enhancements in local communications capabilities would be required to facilitate such communication. The FEIS needs to include more investigation, study and planning if transportation is to be safe for both the environment and the communities within White Pine County.

The DEIS does not appear to address where and how relief drivers will be stationed or where and how these drivers will stop and park their trucks for meals, vehicle maintenance, fuel, etc. In addition, the DEIS does not address the qualifications of drivers and their respective knowledge in handling vehicle breakdowns or equipment failures as a means to mitigate risk. These issues need to be addressed in the FEIS.

The DEIS does not address restrictions in hours of operations for truck shipments as a possible measure to mitigate exposure risk in communities. For example, shipments could be restricted from passing schools at the beginning and end of each school day.

The DEIS does not consider the availability of specialized equipment which may be needed to transfer shipping casks from one vehicle to another while in transient. Delays in availability of such equipment may exacerbate exposure risks. This information must be considered in the FEIS.

The DEIS does not contain an adequate analysis of the special populations (ie. schools, hospitals, jails, prisons, churches, motels, hotels and communication stations) and strategic community facilities (ie. water supply wells and springs) which may be proximate to highway transportation routes. Potential impacts to such populations and facilities and related mitigation measures should be included in the EIS.

The DEIS mentions "uncertain" transportation-related decisions, "potential

transportation impacts" and regulatory agency "attempts" to reduce potential hazards. Specific rail routes, heavy-haul routes and withdrawal lands need to be identified and analyzed as part of this EIS, not in the future. The FEIS must demonstrate how can true environmental impacts be addressed and major transportation decisions made, without this information.

Specific Comments