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Yucca Mountain Energy Secretary Spencer Abraham is preparing to recommend the site to the President, and needs to hold public hearings by law "in the vicinity of Yucca Mountain" in accordance with the Nuclear Waste Policy Act. If the recommendation is approved by the President (highly likely) and is upheld by Congress, Nevada would receive 6-7 shipments of highly radioactive waste daily for 30 years. The project will affect more than 60 million Americans in 43 cities across America along the waste transportation routes, 30 million Americans who buy agricultural food products grown in Amargosa Valley, as well as all Nevadians, particularly those who live 90 miles northeast of the site in the fastest growing city in America (Las Vegas), and those living in rural Nevada including those within 18 miles (Amargosa Valley). 89% of Nevadians are opposed to the project. Yucca Mountain is not suitable:
TALKING POINTS ON THE SITE RECOMMENDATION HEARINGS PREPARED 8/28/01 BY CITIZEN ALERT In 1999, the DOE released its draft Environmental Impact Statement (EIS) for Yucca Mountain and held public hearings in and out of Nevada. Since that time, the DOE has been purportedly been making changes to the EIS and is expected to release the final EIS sometime this fall; most likely November, according to the DOE. The final EIS will be an important basis for deciding whether to recommend Yucca Mountain as the repository. However, based on DOE's schedule, the final EIS will not be released until after the site recommendation hearings. Thus, the public will not have a complete picture of the basis for the recommendation, and will not have the opportunity to see the DOE's response to their comments on the draft EIS. This sidesteps crucial public involvement in this matter. The DOE is planning to hold these hearings and establish the basis of the recommendation using proposed site suitability guidelines. So, the public is being asked to comment on a recommendation that hinges on rules that the DOE has yet to codify. There is no guarantee that the finalized guidelines will be the same as those proposed, so the basis of the recommendation is question. In actuality, there are codified existing site suitability guidelines that would, if the Secretary of Energy were to make a recommendation today, form the only legal basis for site suitability in the recommendation. These existing guidelines would surely disqualify Yucca Mountain. Compounding this problem, these proposed guidelines hinge upon the EPA Yucca Mountain exposure standards that are currently in litigation. If the courts throw out the EPA standards then the proposed site suitability guidelines are also no good. The Department of Energy should have all of the information that forms the basis of the recommendation in a complete package available to the public well in advance of any public process in order to allow people in Nevada and out of Nevada to review all of the necessary information. The public should be privy to all of the information that will go to the President in the statutory required Site Recommendation Report. Due to the technical nature of the subject matter, at least six months should allowed here for review of all documents. People outside of Nevada have a stake in this process since the waste will pass through 43 states potentially impacting 50 to 60 million Americans along transportation routes. There was wide spread criticism during the draft EIS hearings on transportation analysis being inadequate and many people called for the DOE to redo the transportation study. The DOE and nuclear industry would like Americans to believe that Yucca Mountain and the site recommendation is only about Nevada, yet whether the highly radioactive waste can be safely transported across the nation clearly forms part of the basis on the recommendation to the President. Thus, any updated transportation analysis contained in the final EIS, also a part of the basis, will not be available to the public. The DOE issued the notice of the hearings on August 21, 2001 allowing only two weeks to first hearing on September 5. A much greater window of time is needed for people to arrange time in their busy schedules to come and give comment. Further, the DOE also released the Yucca Mountain Preliminary Site Suitability Evaluation (PSSE) report, a 468 page document. IF you ordered this report immediately after it was released, you would only have ten days to review it prior to the Las Vegas hearing. As with the DOE's public process in the past, insufficient time is given to prepare complete comments for the hearings or the end of the comment period, September 20, 2001, in this case. In general, documents as the PSSE serve only to distract the public from the real issues like those discussed above. It seems clear that DOE is moving forward on a site recommendation process with incomplete regulations, an insufficient comment period, and an unavailable final EIS. All of which leads to the same conclusion: that the Department neither wishes for, nor cares about meaningful public involvement. -- Kalynda Tilges
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