NRC NEWS

U.S. NUCLEAR REGULATORY COMMISSION

Office of Public Affairs Telephone: 301/415-8200

Washington, DC 20555-001 E-mail: opa@nrc.gov

Web Site: http://www.nrc.gov/OPA

No. 00-031 February 23, 2000

NRC COMMENTS ON DOE’S DRAFT ENVIRONMENTAL STATEMENT

FOR POSSIBLE WASTE REPOSITORY IN NEVADA

The Nuclear Regulatory Commission staff has submitted formal comments to the Department

of Energy on its draft environmental impact statement (EIS) for a possible future high-level radioactive

waste repository at Yucca Mountain, Nevada.

DOE is the lead agency for considering the environmental impacts for the repository. Under the

Nuclear Waste Policy Act of 1982, the NRC will adopt DOE’s EIS “to the extent practicable” as part

of NRC’s licensing consideration for the repository.

The NRC staff’s comments are organized into three categories. The first consists of four

comments that the NRC believes should be addressed by DOE in the final EIS to make it complete.

The second category consists of four additional comments on issues related to the completeness of the

environmental statement, but the NRC considers these comments to be less significant than the first

four. The third category consists of five comments offered for DOE’s consideration.

In addition, the NRC requests that DOE, in preparing the final EIS, consider relevant technical

comments previously submitted by the NRC in reports on specific technical issues, and in comments

on DOE’s June 1999 Viability Assessment for the repository.

The four NRC staff comments in the first, most significant category point to:

(1) Lack of an integrated and clearly defined proposed action – The draft EIS does not describe

and discuss the environmental impacts of a clearly defined proposed action. Instead, it discusses five

components and various options within each component, drawing separate conclusions on the

environmental impacts for each of these components and options. As a result, it is not clear that DOE

has “bounded,” or fully identified, all the combined potential environmental impacts that could result

from the repository.

The NRC requests that, as DOE prepares the final environmental statement, it prepare an indepth, integrated analysis of a clearly defined proposed action or, at the least, provide sufficient
information and analysis of the various options to demonstrate that the potential environmental impacts

of the repository have been fully considered.

(2) Failure to address fully the cumulative impacts -- The draft EIS does not fully address the

environmental impacts of the repository when added to other past, present and reasonably foreseeable

future actions relating to groundwater use, land use, and cultural and biological resources. For

example, it does not consider the cumulative effect on groundwater of the repository when combined

with future growth of local cities and counties and possible creation of a Timbisha Shoshone Tribal

Homeland with agricultural water rights; the cumulative effect of the repository on land use when

combined with possible land withdrawals by DOE and possible Department of Interior limitations on

land use in Ash Meadows; and the cumulative effect of the repository on biological resources, such as

the desert tortoise, when combined with activities at the Nevada Test Site and Nellis Air Force Range

and growth of local counties.

NRC recommends that DOE augment its analysis of cumulative impacts for resources,

ecosystems and human communities in the final EIS.

(3) Not clear whether non-radiological impacts of transportation within Nevada have been fully

considered – Because DOE’s draft EIS provides a general discussion of transportation impacts, it is not

apparent that non-radiological impacts of transportation within Nevada have been fully identified.

NRC recommends that the final EIS should contain either a complete assessment of a proposed

transportation action, or sufficient information and analyses of the various options to show that the

impacts have been bounded.

(4) Measures to mitigate impacts not thoroughly discussed – The draft EIS discusses dust

suppression measures and strategies to mitigate the impacts of the repository on desert tortoise and

occupational health and safety. The NRC recommends that the final EIS also evaluate the need for

mitigative strategies for water use, economic, social, cultural, biological, and public health and safety

impacts. Moreover, the final EIS should discuss the use of environmental monitoring to assess the

effectiveness of mitigative measures.

A copy of the complete NRC comments on DOE’s draft statement will be available from the

NRC Public Document Room, 2120 L Street, N.W., Washington, DC 205555, telephone: 202/634-

3273. An electronic copy will be available on the NRC web site at

http://www.nrc.gov/NMSS/DWM/eiscomments.htm.

###