April 26, 1999

Dr. Shirley Ann Jackson, Chairman
U.S. Nuclear Regulatory Commission
Washington DC 20555-0001

Dear Dr. Jackson:

     On February 26, 1999, NRC issued a Notice in the Federal Register seeking public comments on proposed changes to the requirements for environmental review for renewal of nuclear power plant operating license. The Notice has information on the transportation of spent fuel to the proposed nuclear waste repository at Yucca Mountain. The Notice incorporates information and findings from a draft Addendum to NUREG-1437.

     The issue of nuclear waste transportation remains of grave concern to Eureka County, Nevada, which is one of the ten affected units of local government under Section 116 of the Nuclear Waste Policy Act of 1982 as amended. On behalf of Eureka County, Nevada, I am submitting the following comments.

     We are disappointed that the NRC was unwilling to extend the comment deadline for this Notice, as we and others had requested, and that the Notice was titled in such a way as to discourage those affected by it from commenting.

     Announcing the Notice at the public information meetings that the NRC held in late March in Las Vegas and Beatty would have been an appropriate time and place to inform the public and units of government about this complex Notice.

     The draft Notice was misleading because it did not mention in the title that the subject matter of the Notice was transportation of nuclear waste to Yucca Mountain.

     The NRC did not do thorough and adequate consultation with the affected units of local government including local governments that might be affected by transportation of nuclear waste to Yucca Mountain.

     The draft report, which NRC is proposing to allow nuclear power plant licensees to adopt, is inadequate. It uses outdated population numbers. It does not thoroughly analyze the impacts of transportation of the nuclear waste in Nevada.

     The draft report does not address the cumulative impacts of all expected spent nuclear fuel and high-level waste shipments to the Yucca Mountain proposed repository site. In addition to the 50,185 truck shipments of commercial SNF (75,278t shipments with license renewal) , the report must consider the additional impacts of shipments of DOE-owned spent fuel (including naval reactor fuel), shipments of vitrified civilian and defense high-level wastes, and shipments of miscellaneous wastes requiring geologic disposal.

     NRC should not allow the report to be attached as a generic document. Instead, in order to renew the license, NRC should require a specific analysis of the impacts of transporting the waste from the power plant site to the proposed Yucca Mountain repository location.

     Thank you for considering our comments.

Sincerely,

Abigail C. Johnson

Abigail C. Johnson
Nuclear Waste Advisor

cc:
Leonard Fiorenzi, Eureka County
AULGs
Joe Strolin, NWPO
Chip Cameron, NRC