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DEQ.utah.gov -Utah Department of Environmental Quality

The Official Web site of the Utah Department of Environmental Quality

Comments Submitted by the State of Utah

September 20, 2000

on the

DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS)

For the Construction and Operation of an Independent Spent Fuel Storage Installation on the Reservation of the Skull Valley Band of Goshute Indians and Related Transportation Facility in Tooele County, Utah.

Introduction

Procedural Comments

  1. A comment period of ninety days is too short for a document and project of this magnitude.
  2. Three hearings, all in Utah, are far too few for a project with large and nationwide impacts.
  3. DEIS and close of public comment period are premature
  4. BLM can't participate in this process given the 1999 National Defense Authorization Act

General Comments

  1. NRC does not have statutory authority to license this facility.
  2. BLM does not have statutory authority to make any change in its Resource Management Plan.
  3. This DEIS and related process cannot support BLM's proposed action.
  4. Proposed action and process violates BIA statutory authority.
  5. The cost benefit analysis is not impartial, but is one-sided, weighted heavily in favor of the PFS facility, and fails to consider many important negative impacts.
  6. Failure to analyze incompatibility with surrounding military activities.
  7. Failure to include the Department of Defense as a consulting agency.
  8. Analysis of alternatives does not meet the requirements of NEPA, and implementing regulations
  9. The DEIS does not demonstrate a need for the proposed facility.
  10. The DEIS does not support the need for such a large facility.
  11. The DEIS fails to adequately address obvious safety and environmental concerns regarding the rail spur.
  12. Risks and costs of transportation are not adequately discussed.
  13. Inappropriate reliance on the waste confidence decision means many significant impacts are not addressed.
  14. Mixed oxide fuel poses special storage and disposal problems that have not been addressed in this DEIS.
  15. Facility's lack of a contingency plan for spills, and a realistic closure plan means that there is a risk of contamination that has not been described.
  16. Impacts of PFS's claimed limited financial responsibility and liability not described.
  17. Dry cask technology presents risks not discussed.
  18. The risks and consequences of sabotage must be discussed.
  19. Analysis of required federal and state permits is incorrect.
  20. The DEIS's analysis of risks associated with seismic instability is legally and factually inadequate.
  21. Future land use is inadequately analyzed for this fast-growing area.
  22. Construction schedule not provided.
  23. Adequacy and cost of local emergency services, including firefighting capability, not discussed.
  24. Constancy of electrical power sources may not be assumed.
  25. Potential impacts of lighting on the facility have not been described.
  26. Failure to provide "hot cell" creates considerable risks that have not been considered in the DEIS.
  27. Impacts on wildlife inadequately described.
  28. Impacts on historical resources inadequately described.
  29. Impacts on proposed wilderness inadequately described.
  30. Reclamation of rail spur not addressed.
  31. Impacts to nearby state lands, private lands, and R2477 roads not addressed.
  32. Steps to protect ground water not taken.
  33. Monitoring proposed is inadequate.
  34. Failure to adequately address Alternative Action-Federal Government Taking Possession of Spent Nuclear Fuel
  35. The environmental consequences of the rail line cannot be limited to the immediate, proposed rail spur.
  36. Failure to address impacts of rise in Great Salt Lake.
  37. The DEIS fails to address significant impacts on highways and highway users.
  38. Agencies have failed to address impacts of geologic hazards along the proposed rail spur.
  39. The DEIS does not consider impacts to Wasatch Front
  40. Greater than Class C Wastes

Specific Comments

Additional Comments

Attachments List

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