In addition, the group claims the DoE’s recently revised guidelines for selecting a site have been tailored to ensure the Nevada site can qualify.
The statements were included in comments submitted by Public Citizen to the DOE about its Draft Environmental Impact Statement for a Geologic Repository for Nuclear Waste at Yucca Mountain, Nevada (DEIS), and the department’s proposed rule change regarding the siting guidelines for the proposed repository.
“The environmental impact statement is an incomplete assessment of the environmental risks associated with a nuclear waste repository at Yucca Mountain, and as such, the statement should be withdrawn and completely rewritten,” Amy Shollenberger, a senior policy analyst for Public Citizen’s Critical Mass Energy Project, said.
Shollenberger outlined several flaws with the DEIS:
- the failure of the impact statement to adequately address the risks and costs associated with the nuclear waste shipping that will be necessary if the repository is approved. These include decreased property values, risk from accidents and risk from continual radiation exposure of people living on the transportation route
- the impossibility of accurately determining the risks of a Yucca Mountain repository until one of several specific designs is chosen
- the failure to fully assess the socio-economic and environmental justice issues associated with a nuclear waste repository
- the unrealistic nature of the ‘No-Action Alternative’. Shollenberger says this scenario – in which no repository is built at all – is unrealistic and fails to provide a baseline for comparison to the proposed action. Shollenberger says the scenario is being used as a scare tactic to justify Yucca Mountain’s inadequacies
- the DEIS’ incomplete assessment of the cumulative impacts that a nuclear waste repository at the Yucca Mountain site would have on southwestern Nevada. Shollenberger says this area is already overburdened with nuclear wastes and underground nuclear weapons testing, and the effect of combining these burdens with any impacts from a repository at Yucca Mountain must be considered
- the inaccessibility and verbal difficulty of the report – a deterrent to citizen participation before government agencies
Shollenberger’s second set of comments, which address the proposed rule change on the siting guidelines for Yucca Mountain, claim that the proposed rule has neither a scientific nor a legal basis. Therefore, Public Citizen has requested that this proposed rule be withdrawn.
The new rule would change siting guidelines issued in 1984 specifying certain characteristics (eg. hydrology, geophysics, seismic activity) that would disqualify any site from consideration as a nuclear waste repository. Evidence shows that Yucca Mountain currently would not meet the 1984 guidelines. DoE’s proposed rule would make it easier for Yucca Mountain to qualify, thus removing a strong barrier to the approval of Yucca Mountain as a storage facility.
“The DoE’s argument raises a presumption that the DoE is attempting to change the guidelines because it has become clear that Yucca Mountain does not meet the earlier criteria,” Shollenberger said. “This is a blatant attempt to save a failed programme and sustain the wrong decision regarding Yucca Mountain’s suitability as a nuclear waste repository.”