Testimony of Sandy Green
Board of Eureka County Commissioners
on the Adequacy of the Draft Environmental Impact Statement
for a Geologic Repository for the Disposal of Spend Nuclear Fuel
and High-Level Radioactive Waste
at Yucca Mountain, Nevada
December 9, 1999
Crescent Valley, Nevada

     My name is Sandy Green, and I am the vice-chairman for the Board of Eureka County Commissioners. I am here today on behalf of the Eureka County Commission to make some preliminary comments on the adequacy of the Department of Energy's Draft Environmental Impact Statement (DEIS) on Yucca Mountain. The Commission chairman will provide additional comments at the evening hearing.

We appreciate the Department of Energy's willingness to come to Crescent Valley to hold these hearings in the area where the impacts could be. It means that DOE will be hearing today from local residents who could be affected by the proposal to build a branch rail line to transport high-level radioactive waste and spent nuclear fuel to Yucca Mountain.

Eureka County is one of the ten "affected" units of local government under Section 116 of the Nuclear Waste Policy Act as amended. The County Commission is very concerned about the impacts that a proposed rail route could have on our county, especially Crescent Valley, and that the DEIS does not do a thorough or adequate job of identifying those impacts.

Economic development
The DEIS does not adequately address the potential effects that this project could have on property values within our county. Our concern has several dimensions. We are concerned about the potential loss of market value because of the stigma of a nuclear waste rail line in the county. With the strong agricultural base in the county, the nuclear stigma could affect not only property values but also crop prices. We are also aware that such stigma can stymie our efforts to diversify the local economy and attract new enterprises to the county not to mention retaining existing businesses. The recent nuclear accident in Japan is a case in point, where both tourism and potential business were negatively impacted. The term for this is "disinvestment" and we believe that this project could have that sort of impact on our county and our state.

Flood plain
One of the recurring comments I hear is that the proposed rail line is sited in the Flood plain, in the playa which floods up to four feet in wet years. This DEIS contains information which has not been verified or "ground truthed." The information in the document is insufficient to make and informed decision about which rail route to select. Flooding is an example of this.

Effects on Native Americans
Page 3-114 of the DEIS states that Native Americans live in the vicinity of two of the candidate rail corridors- Jean and Valley Modified. This statement should be rewritten to acknowledge that the Western Shoshone Dann sisters live in Crescent Valley in the vicinity of the proposed Carlin route.

Need for current data
The DEIS uses 1990 census data which is clearly outdated for Nevada, a fast growing state. Current data is available from the state demographer and should be used in the DEIS. Do not penalize Nevada for its growth rate or for the fact that this project is being proposed before the next national census.

Agency cooperation and consultation
Because over 87% of Eureka County is managed by the Bureau of Land Management (BLM), it seems that more input is required from that agency regarding the variety of impacts that the rail route could have on land and resources that they manage. We were shocked to read in Appendix C that DOE only met once with BLM and that there was no ongoing communication or interaction mentioned regarding DOE's multi-faceted proposal.

We hope that BLM would not hold DOE's proposed action to any lesser standard than they require of the mining and the ranching industries.

I have here a current DEIS from the Cortez South Pipeline project which was submitted to the Commissioners. This DEIS has the kind of detailed, site specific information that DOE should be gathering for each proposed rail corridor at this time in order for there to be adequate information for route selection.

Nevada transportation
Another area where the DEIS is deficient is in its treatment of existing rail and highway within Nevada. For example, from West Wendover to Beowawe, the interstate and the Union Pacific rail line go through several communities and cross the Humboldt River. You would never know that from reading this document.

A major flaw in this DEIS is that the Department of energy appears to want to disconnect the development of Yucca Mountain as a repository from the transportation of nuclear waste. As it stands now, DOE is not funding transportation development. This DEIS reflects that priority. Since the origins and destination of the nuclear waste are known, the DOE should have identified specific routes in the DEIS, which would have informed communities throughout the country of the DOE's plans.

This DEIS is not adequate to make an informed decision on modes and routes, even though DOE states that they intend to make routing decisions based only on the information in this DEIS.

We believe that the DEIS is inadequate and call upon the Department of Energy to release a new draft for public comment which corrects these deficiencies. It is essential that the public and the affected units of local government have an opportunity to review and comment on the changes that DOE will make. A new draft will ensure that the public has a voice.

Thank you.

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