The Shundahai Network :A Decade of Resistance

URGENT ACTION ALERT!! DEADLINE APPROACHING!
YUCCA MOUNTAIN, SACRED TO THE SHOSHONE & MAJOR FAULT ZONE, IN
IMMINENT DANGER!
DEPARTMENT OF ENERGY MOVES PLANS FORWARD TO TURN YUCCA MOUNTAIN INTO
NUCLEAR WASTE REPOSITORY.
PUBLIC COMMENT PERIOD DEADLINE JANUARY 10, 2008.

Public hearings have not been well attended, statements mostly in
favor of the plan to put all of the nuclear waste in the country in
this one sacred place. Activists were told that if we do not go on
record with a statement, we will have no legal recourse later on.
Local papers & media spin have recently stated that opposition to the
nuke dump had dropped of since the passing of Corbin Harney. The
nuclear reps are confident to the point of acting like it's a done
deal.  WE KNOW THAT'S NOT TRUE! LETS PROVE THEM WRONG! TAKE ACTION &
MAKE YOUR COMMENT NOW!!

 "The eyes of the elders are on us.  The fate of the unborn is
rolling toward the cliff, the voice of Corbin Harney is ringing in my
ears, "It's on your shoulders now...".   Info from Bear Dyken.
mdyken@goldrush.com.

Yucca Mountain is sacred to the Shoshone as an herb gathering site,

H
ME: Healing Ourselves & Mother Earth www.h-o-m-e.org Breaking the Silence of Nuclear Denial
H
ME Talking Points for Yucca Mountain
10/07 Draft Supplemental Environmental Impact Statements
There are actually 3 draft NEPA documents that DOE has issued for review and comment. One is a supplement
to the 2002 Yucca Mountain final Environmental Impact Statement (EIS). The other two are combined in one
document dealing with (a) the evaluation of potential rail corridors to Yucca Mountain and (b) the actual
selection of a rail alignment within the proposed Caliente corridor.
The Draft Repository SEIS
Site Characteristics

It is isolated from concentrations of human population and activity. Pahrump and Las Vegas NV are among
the fastest growing populations in the U.S. Amargosa Valley, at the base of the mountain is home the
State’s largest dairy, providing milk all the way to Los Angeles. Amargosa Valley shares the aquifer with
Yucca Mt.

It is on land controlled by the Federal Government. Some of the land is controlled by the U.S. Air Force
and all of it is within the treaty lands of the Western Shoshone nation, ratified by Congress in 1863 and
recently upheld by the UN Committee to End Racial Discrimination, naming the Yucca Mt. Project as part
of ongoing human rights violation against the Western Shoshone.

Yucca Mountain is in one of the most arid regions in the U.S. When rain does come, it is often in flash
floods that travel rapidly. Any escaping radionuclides that reach the surface can travel down the Amargosa
River channel. Climate conditions also appear to be changing rapidly and a high-level nuclear waste
repository must be able to isolate the waste for hundreds of thousands of years. Throughout the lifetime of
the waste, the region is expected to experience future climate cycles that would include ice ages and wetter
conditions.

Groundwater beneath Yucca Mountain flows into a “closed” hydrogeologic basin This” closed basin”
covers thousands of square miles, and is inhabited by many communities, the Timbisha Shoshone Tribe, and
Death Valley National Park, visited by nearly 1 million visitors a year, all of whom rely on groundwater for
survival. The Amargosa River, which is fed by all pathways on both sides of Yucca Mt., is considered the
third largest in the western U.S. and parts of it run year round above ground. Research conducted by Inyo
County, CA, defines fast pathways from Yucca Mt. to area springs used for drinking water by many.
Transportation, Aging and Disposal (TAD) Canisters

The draft repository SEIS deals primarily with DOE’s decision to alter the design of repository surface
facilities to incorporate the concept of Transportation, Aging and Disposal (TAD) canisters. TADs are
intended to simplify handling of spent fuel at the repository by having waste loaded into welded canister at
the reactor sites. Then, using a series of different overpacks, the TADs can be stored at the reactors,
transported to the repository, stored or aged at the repository surface facility, and ultimately disposed of
underground, all without ever having to rehandle the actual spent fuel.

While in theory, TADs would simplify repository surface facility design and operations (by reducing the
need for extensive SNF handling facilities), the reality is that the effect is to transfer risks and impacts from
the repository to the reactor locations where the handling operations would take place. The final SEIS needs
to comprehensively assess risks and impacts to workers, facilities, communities and the environment at all
of the reactor locations where TADs would have to be used.

TADs also complicate waste transportation. Many reactor sites already have (or are in the process of
implementing) on site dry storage facilities using multipurpose (storage/transport) container systems that are
not compatible with TADs and would require either repackaging of the SNF into TADs prior to transport or
the use of non-standard transport vehicles.
H
ME: Healing Ourselves & Mother Earth www.h-o-m-e.org Breaking the Silence of Nuclear Denial


TADs can only be shipped via rail or by very large, oversized/heavy-haul trucks. Because rail access is
NOT available at Yucca Mountain, and there is not guarantee it ever will be, the SEIS should have assessed
the impacts of a TAD based transportation system that can not use rail as the primary mode of transportation
to Yucca.

There are no final TAD designs in the draft SEIS, so it is difficult to assess how TADs will impact the
repository system, including the transportation components.


Costs and financial arrangements for the use of TADs are unknown.

The proposed TAD system is not compatible with dry storage systems currently in use at civilian nuclear
power plants.

Many utilities have specific problems with use of the proposed TAD system at specific reactor sites.

DOE offers no meaningful alternative to the proposed TAD canister system.
Draft Rail Alignment SEIS

The draft Rail EIS includes the Mina Rail Corridor as a “non-preferred alternative.” However, NEPA
requires that alternative evaluated in an EIS be capable of being selected –i.e., they must be viable
alternatives. Because to Walker River Paiute Tribe has refused permission for DOE to use any portion of its
reservation for the proposed rail spur (and without such permission the Mina route cannot be used), it is
inappropriate for DOE to have included Mina as an alternative for comparing rail corridors in the draft EIS.
The mina route is not viable and should have been excluded from the EIS.

The Rail DEIS No Action Alternative is also inappropriate and perhaps unlawful. If DOE does not select
the Caliente or Mina rail alignment, the DEIS states that the future course “is uncertain.” In fact, if rail
access to Yucca Mountain is not implemented, the NO Action alternative would be legal-weight truck
shipments.

The repository SEIS should have evaluated the impacts of a legal-weight truck transport system nationwide
and within Nevada. 
DSEIS Does Not Adequately Address Transportation Safety and Security.

It does not consider worst case accidents - such combinations of factors “are not reasonably foreseeable”.


It underestimates consequences of severe accidents involving long duration fires.

It underestimates consequences of terrorist attack.


It dismisses potential for human error to exacerbate consequences of accidents or terrorist attacks.


Dismisses potential for unique local conditions to exacerbate consequences of accidents or terrorist attacks


The rail DEIS does not fully evaluate repository shipments into NV from CA or the impacts to Northern
Nevada (especially the Reno/Sparks/Washoe County area.

Under Proposed Action, 9,500 rail casks and 2,700 truck casks to Yucca Mountain over 50 years; if no
second repository, 24,000 rail casks and 5,000 truck casks.

Only 8% of rail shipments enter NV from CA if Caliente rail line is developed, compared to 21% if Mina
rail line is developed; 32 % of truck casks enter NV from CA.

The rail DEIS ignores potential for larger number of rail cask shipments into NV from CA for Caliente or
Mina options (>4,400, or >45% of total under proposed action).


The rail DEIS Ignores potential for large number of LWT shipments into NV from CA if there is no rail
access to Yucca (>24,000, >45% of total under proposed action).
Some General Comments

DOE’s selection of the Caliente Corridor is not supported by the information presented in the Draft SEIS –
the information in the DEIS does not adequately compare Caliente with other viable rail corridors.

DOE’s study of the Mina Corridor as a “non-preferred alternative” is not warranted given the Walker River
Paiute Tribal Council’s withdrawal of support.


Because DOE has now announced that the rail line it proposes would be a “Shared Use” line, the USDOT
Surface Transportation Board should be the lead agency that prepares the Rail Alignment EIS.

The DOE contention that non-rail shipments would be made by over-weight trucks is unsubstantiated, and
the impacts of the use of overweight truck in Nevada and elsewhere are not analyzed.due by 1/10/08