The document should thoroughly analyze the impacts on rural communities and residents, including the impacts of accidents involving the release of radioactive material. The document should identify the schools, hospitals, and other community facilities that could be impacted by transportation accidents. The document assumes that people who live in urban areas need to be protected from health hazards and people who live in rural areas, because of population, are insignificant. It is unacceptable to solve an urban public health problem at the expense of rural residents. Emergency Response Analysis is Inadequate Finally, the document is inadequate in its analysis of the availability of emergency response equipment and capability, including medical response.
Most rural communities have volunteer emergency responders with limited training and equipment.
The document should analyze whether the benefit of moving the shipments out of the Las Vegas Valley is worth the risk of accidents in rural areas with minimal or limited capacity to respond adequately and promptly to an accident involving the release of radioactivity. If DOE goes forward with issuing a Finding of No Significant Impact, it must be accompanied by a mitigation action plan to address these emergency management inadequacies in affected rural communities. The proposal to establish an intermodal facility requires a full Environmental Impact Statement. The proposal to route low level radioactive waste on rural highways will create significant impacts on rural communities. We appreciate the opportunity to comment on this draft document.