Nuclear Waste Storage CP

Nuclear Fuel Storage Counter Plan 1
Table of Contents:
CounterPlan
Solvency:
1. Inadequate Storage Capacity; Yucca Can Only Hold 63,000 Metric Tons of Waste
Disadvantages:
Seismic Threats:
1. YM is an Earthquake Zone
2. Seismic Threats At Yucca
Impact: Water Under Yucca Used by Farming Community
3. Volcanic Hazard
Impact: Volcanism Would Release Massive Amounts of Radioactivity
Impact: Yucca Near Las Vegas, Los Angeles, Nellis AF Base
Transportation Risks:
4. Containers for Transportation not Adequately Tested; Unsafe
Guidelines Re-Written Unsafely for YM:
5. Regulations Re-Written When Yucca Failed to Meet Standards
6. Politics Trumped Science in Opening Yucca
7. Regs Lowered Without Consideration for Population Risks
YM Doesn’t Provide for Geologic Waste Isolation:
8. Yucca Mountain Not Adequate for Long Term Geologic Isolation
9. Yucca Cannot Comply With Geologic Waste Isolation

10. Potential for Human Intrusion of Site
11. Yucca Will Cost $60-100 Billion
12. Nuclear Fund Won’t Cover Costs
YM Quality Low:
13. Yucca Does Not Meet DOE Siting Guidelines
14. Quality Assurance Deficiencies
15. Container Lifetime, Radionuclide Dilution in Groundwater Untested

Arjun Makhijani, (Ph.D in Engineering, specializing in nuclear fusion, President of the Institute
for Energy and Environmental Research), Independent Institute Recommends Alternative
Nuclear Waste Plan, June 4, 2002 http://www.ieer.org/comments/waste/yuccaalt.html
"Our plan, which is based on more than two decades of analysis and experience on radioactive
waste management policy, includes the placement of spent fuel in hardened storage at or near the
point of generation for a period of about 50 years. This would reduce the risk of large-scale
catastrophe in case of a terrorist attack," explained Dr. Arjun Makhijani, author of the plan and
president of the Institute for Energy and Environmental Research (IEER) in Takoma Park,
Maryland.
"Meanwhile, ten years of scientific and engineering work would be undertaken, on questions
like, 'What are the natural geologic conditions that retard the movement of radionuclides for long
periods?'," Dr. Makhijani continued. "More basic research on various geologic settings is needed
before sites can be scientifically screened. Site selection should not begin until this preliminary
work has been done."
Arjun Makhijani, (Ph.D in Engineering, specializing in nuclear fusion, President of the Institute
for Energy and Environmental Research), Independent Institute Recommends Alternative
Nuclear Waste Plan, June 4, 2002 http://www.ieer.org/comments/waste/yuccaalt.html
"In light of the deficiencies of the Yucca Mountain site and the risks of transporting spent fuel
without proper design and testing of casks, IEER has put forth a plan for nuclear waste
management, with due consideration to terrorism risks, that would greatly reduce on-site risks
and increase the likelihood of a far better repository program," said Dr. Makhijani. "Our plan
would have the benefit of greater public acceptance, especially if it were coupled with
termination of the waste stream as nuclear power plant licenses expire."
IEER NUCLEAR WASTE MANAGEMENT PLAN

June 4, 2002
IEER advocates the following program be carried out by an institution that does not have the
conflict of interest that the U.S. Department of Energy does, and under more stringent public
health and environmental protection standards than those currently in effect:
Interim Management
Interim Hardened On-Site Storage (HOSS) (different from spent fuel pools and dry casks now
used) should be used for all spent fuel that can be moved out of pools. Pool storage should be
minimized. No new above-ground dry storage of the present varieties should be licensed. Current
dry storage should be converted to HOSS. The federal government should pay for HOSS at
closed power plant sites since it has defaulted on its obligation to begin taking the waste on
January 31, 1998, and has large amounts of ratepayer money dedicated to waste management
that it has not spent.
Goals: Hardened On-Site Storage should be able to withstand most terrorist attacks without
significant off-site releases. A second level goal is to prevent catastrophic off-site releases in
case of even severe attacks. There could be defense in depth as part of the system.
The technology to accomplish HOSS is available.
Interim Hardened On-Site Storage (HOSS) should meet the following criteria:
1. It should not result in catastrophic releases and should be able to resist almost all types of
attacks. The amount of releases projected in even severe attacks should be small enough that the
storage system would be unattractive as a terrorist target.
2. It should be able to withstand a direct hit by a large commercial airliner full of fuel or anti-
tank weapons without catastrophic offsite releases.
3. The individual canister locations should not be easily detectable from offsite.
On-site storage would be needed for about 50 to 60 years -- not much different from what is
projected to occur at present.
Long-term Management
The long-term repository plan should proceed as follows:
Ten years of the following scientific and engineering work:
1. Research on natural geologic conditions that retard the movement of radionuclides for long
periods.
2. Development of materials that mimic these natural geologic conditions ("Natural analog"
materials).
3. Research on geologic environment types that would match the characteristics of these natural
analogs.
4. Intensified basic scientific research on the properties of the most important radionuclides
under a variety of laboratory conditions.
After this initial work, the process of selecting two or three repository and natural analog types
would be initiated for concentrated work (10 years). Then site selection (10 years).
If the process is sound, disposal could in principle happen in the twenty years to follow. The total
time for complete disposal of fuel from existing power plants (40 year license) would be roughly
50 years, maybe sixty. If the power plants are closed down the overall timetable would not be
longer than envisioned for Yucca Mountain now.
Inherency:
Yucca Cannot hold more than 63,000 tons of waste
Kevin Kamps, Nuclear Information & Resource Service, The Science and Politics of the
Proposed High-Level Radioactive Waste Dump at Yucca Mountain, Nevada, USA, Nov. 28, 2003
http://www.nirs.org/factsheets/yuccaitaly.htm
8. Yucca as “secure centralized storage” to prevent terrorism is a myth:
Yucca cannot legally hold more than 63,000 tons of commercial high-level waste. Around
45,000 tons exist already. By 2011, 63,000 tons will exist, meaning Yucca would be full before it
even opens. Ongoing operations after that means whatever gets shipped off to Yucca would be
replaced with new waste on-site at reactors. Decades from now, we’d be right back where we
started, with insecure storage across the USA.
Disads:
1. Yucca Mountain is an Earthquake Zone:

Yucca is a major earthquake zone. Dozens of fault lines crisscross the area, with two directly
intersecting the proposed dumpsite. Many hundreds of quakes have struck near Yucca in recent
decades, damaging DOE facilities, derailing trains that could one day be used to haul nuclear
waste, and threatening to collapse access and burial tunnels.
2. Seismic Threats at Yucca

Nevada Agency for Nuclear Projects Report, State of Nevada and Related Findings Indicating
that the Proposed Yucca Mountain Site is not Suitable for Development as a Repository, 1998
( . . . “research findings generated as a result of Agency independent studies addressing key
technical and site suitability issues associated with the proposed Yucca Mountain high-level
nuclear waste repository site.”)
A key health and safety issue at the Yucca Mountain site is the effect of earthquake- induced
vibratory ground motion and fault movement during the decades-long operational phase of the
repository and the 10,000 or more years after closure of the facility. Seismic events, individually
or cumulatively, have the potential to compromise in unpredictable ways the integrity of the
engineered barrier system (waste containers, backfill, seals, etc.), the surface facilities for
handling and packaging the radioactive waste (storage and transfer pools, etc.), and perhaps most
important, the natural barriers of the site (through changes in site geology and hydrology) during
the hazardous lifetime of the waste.
State researchers have concluded that a magnitude 6.5 to 7.0 earthquake is likely in the vicinity
of Yucca Mountain in the next 10,000 years. Of the 33 known Quaternary faults (less than 2
million years old) in the vicinity of the site, at least five contain observed volcanic ash that
provides evidence of contemporaneous volcanic eruption at the young Lathrop Wells volcano 9
miles south of the site with fault rupture events at the site. A recognized characteristic of Great
Basin faulting events is that all ground surface fault ruptures are the result of earthquakes with a
magnitude of at least 6.0 - 6.5.
During the period of historical earthquake record for southern Nevada, 1868 to present, there
have been approximately 250,000 earthquakes in the region with magnitudes ranging from less
than 1.0 to 7.8. In the 20-year period, 1976-1996, there have been 621 seismic events with a
Magnitude 2.5 or greater, within 50 miles of Yucca Mountain. A Magnitude 3.6 earthquake was
recorded in 1948 on a fault on the southeast boundary of the site. The most notable event was the
June 29, 1992 Magnitude 5.6 Little Skull Mountain earthquake on a previously unrecognized
fault, that occurred 12 miles from the site. This earthquake, along with a number of others in the
western U.S. at the same time, is considered to have been triggered by the Magnitude 7.4
Landers earthquake in southern California.
Earthquake and active fault studies provide information necessary to define the regional tectonic
framework of Yucca Mountain and the deep geologic structure beneath the site. There is
considerable scientific debate over which of a number of possible tectonic models best represents
the site area, and because of recognized uncertainties and gaps in regional knowledge, the debate
is likely to remain unresolved. A regional model incorporates knowledge of deformational
processes, hydrologic processes, and volcanic processes that have operated in the past and are
operating at present. Recent independent investigation suggests that the rate of ground
deformation in the Yucca Mountain area is about 20 times greater than Yucca Mountain Project
investigators had previously determined. If correct, this has potential implications of increased
frequency and magnitude for future seismic and volcanic events. Further independent work on
surface deformation is in progress.
Impact: Water Under Yucca Used by Farming Community

All that seismic activity has fractured and fissured Yucca’s rock, creating fast flow pathways for
water infiltration. Water will eventually corrode waste burial containers, releasing deadly
radioactivity into the underground drinking water supply used by a thriving farming community
downstream.
3. Volcanic Hazard
Volcanic Hazard
Future volcanic disruption of the Yucca Mountain site is a critical concern relative to the safety
of a Yucca Mountain repository. Volcanoes occur when magma (molten rock formed beneath the
earth's crust) intrudes into the crust and flows out onto the earth surface. Earthquakes, fault
movement, and hydrothermal activity including hot springs are some of the geologic effects
caused by intrusive volcanic activity. The earth's crust is known to be relatively thin in the Yucca
Mountain region, and volcanism has occurred in the region for about the last 12 million years.
There is a continuing dispute among Yucca Mountain Project scientists, NRC scientists, and
State scientists about the probability of future volcanic disruption of a Yucca Mountain
repository. The probability of volcanic disruption estimated by State and NRC scientists is two to
three orders of magnitude greater than that estimated by Project scientists. Even relatively small
differences in the projected probability of volcanic disruption of the repository result in
significant differences in calculated individual doses and risk in the repository performance
assessment. According to State scientists, a volcanic eruption in the Yucca Mountain area is
probable during the design life of the repository, although the location of the future activity
cannot accurately be predicted. In contrast, Project scientists say that the probability of volcanic
disruption of the repository is so low (because of disputed interpretations of the area geology)
that the risk should be dismissed from consideration in a Yucca Mountain performance
assessment. Efforts to resolve the controversy continue to fail, primarily because of a lack of
sufficient information, especially in the unresolved matter of the regional tectonic model
discussed above. It is unlikely that this dispute that affects any suitability determination and
compliance with licensing rules can be resolved in the near term for reasons described above.
Impact: Volcanism Would Release Massive Amounts of Radioactivity

Volcanism threatens the flooding of the proposed waste dump with superheated water and even
lava, which would release massive amounts of deadly radioactivity into the surrounding
environment.
Yucca’s geology is so bad that building a dump there would require complete abandonment of
the original concept of deep geologic disposal. Engineered barriers would have to provide all the
radiation containment, begging the question: why build the dump there at all?
Impact: Yucca Near Las Vegas, Los Angeles, Nellis AF Base

Yucca is near Las Vegas and not far from Los Angeles. It’s immediately next door to Nellis Air
Force Base, the Nevada nuclear weapons test site, and mining operations, threatening accidental
or intentional crashes or detonations involving DOE’s proposed surface facilities for handling
and storing wastes. Yucca is on Western Shoshone Indian land, raising environmental justice
objections to waste dumping there.
4. Transportation Dangerous
6. Dangers of transportation: “mobile Chernobyls”:
Yucca’s opening would launch an unprecedented program of high-level radioactive waste
transportation, many tens of thousands of truck, train and barge shipments on highways, rail
lines, and waterways across 45 states. The shipping containers are not adequately safety tested
and are vulnerable to severe accidents and terrorist attacks, risking the release of catastrophic
amounts of radioactivity in major population centers along the transport routes. To avoid a
popular uprising, government agencies and the nuclear power industry have kept the routes to be
used secretive.
5. Regulations Re-Written When Yucca Failed to Meet Standards

4. Changing the rules in the middle of the game: weakening environmental protection standards
when Yucca fails to meet the original ones:
When Yucca has been unable, due to its poor geology, to live up to previously established
federal safety regulations, they have simply been re-written or done away with altogether.
Environmental Protection Agency regulations for repositories limiting releases of radioactive
gases that Yucca could not meet were simply done away with for Yucca; re-written, Yucca-
specific regulations allow for 18 kilometers of radiation contamination of groundwater, an
unprecedented undermining of the Safe Drinking Water Act that threatens the farming
community downstream that depends on Yucca’s aquifer. And less than a month before its
official decision finding Yucca “suitable” for nuclear waste dumping, the Department of Energy
simply eliminated a 17 year old site suitability regulation that stated if water could travel through
a proposed repository and back out into the environment in less than a thousand years time, that
site must be disqualified from any further consideration. DOE’s own studies have shown that
Yucca cannot live up to that regulation, and over 200 public interest organizations petitioned
DOE in 1998 to enforce its own regulations and disqualify Yucca. But DOE simply erased the
regulation in 2001.
6. Politics Trumped Science in Opening Yucca
5. Politics trump science: corruption of the decision-making process:
Despite major conflicts of interest at the Yucca Mountain, nearly 300 technical studies being
incomplete, and DOE’s “weak to moderate” scientific basis, the project won congressional and
presidential approval despite Nevada’s objection. The nuclear power industry spent many tens of
millions of dollars in the form of direct Capitol Hill lobbying, nationwide ad campaigns, and
campaign contributions to federal office seekers to influence the Yucca votes. More recently,
revelations that whistleblowers at the Yucca Mountain Project and in the waste shipping cask
manufacturing industry have suffered severe harassment increase concerns about short cuts on
safety.
7. Regs Lowered Without Consideration for Population Risks


CHANGING RULES AND STRATEGIES FOR THE YUCCA MOUNTAIN SITE
Instead of disqualifying the site for failure to meet the EPA repository health and safety standard,
DOE launched an effort to convince EPA that its standard should be relaxed because, while the
carbon-14 releases would violate the standard, the resultant individual dose from the releases
would be negligible. This argument ignored the long-term population risk that would result from
these carbon-14 releases to the atmosphere.
EPA rejected the request to modify the standard. This ultimately resulted in Congress, in the
1992 Energy Policy Act, directing the EPA to write a new standard specifically for the Yucca
Mountain site. The standard was to be one that limited doses to individuals affected by the
emplaced waste rather than limiting releases of radionuclides from the repository. Population
risk was not mentioned. Congress further directed the Commission to revise its repository
licensing rule, as necessary, to be consistent with the new EPA standard.
To date, the EPA has not issued a new proposed Yucca Mountain standard (40 CFR Part 197) for
public comment and final promulgation. But the NRC staff, following the direction of the
Commission, has recently recommended a site specific repository licensing rule to the
Commission for publication as a Proposed Rule for disposal of highly radioactive waste at Yucca
Mountain (10 CFR Part 63). The staff recommendation includes a limit on radiation doses from
the repository to individuals located 20 kilometers from the repository boundary. The
recommendation, also at the direction of the Commission, does not contain a separate
groundwater standard limiting annual doses received from the underground source of drinking
water. The NRC staff-recommended individual dose limit from the repository is six times greater
than the national and State drinking water standard.
8. Yucca Mountain Not Adequate for Long Term Geologic Isolation

State of Nevada Agency for Nuclear Projects, Plutonium Migration Has Significant Implications
for Waste Isolation at Yucca Mountain
http://www.state.nv.us/nucwaste/yucca/plut01.htm
A repository for the permanent disposal of spent nuclear fuel and high-level radioactive waste
will need to isolate over 70,000 metric tons of radioactive materials from the environment and do
so over the period of at least 10,000 and perhaps as many as 100,000 years. Of the radionuclides
in a repository, there are nearly 1,000 tons of plutonium, which has a half life of 24,400 years.
That means plutonium decays very slowly and remains extremely toxic for hundreds of
thousands of years - hence the need for long term geologic isolation.
In assessing the Yucca Mountain site's ability to safety and adequately isolate radionuclides from
the environment, DOE must assume that the canisters holding the spent fuel and HLW will
deteriorate and release their contents before the longer lived isotopes (like plutonium) have
decayed to anywhere near safe levels. The speed at which water can disburse these materials into
the underground aquifer system becomes critical in determining whether the site, in fact, meets
the requirements for "permanent" disposal. The new finding by the Lawrence Livermore and Los
Alamos researchers suggests that the geologic and hydrologic environment at and around Yucca
Mountain will not be able to isolate materials like plutonium from people and the environment
for the time necessary.
9. Yucca Cannot Comply With Geologic Waste Isolation

The NWPA requirement that geologic considerations be primary in repository site selection
implements the original and long-held intent that the natural barriers, not the engineered barriers,
of a deep geologic repository be the primary defense against loss of waste isolation. The Yucca
Mountain site cannot comply with this fundamental intent for geologic waste isolation because a
natural characteristic of the site is rapid fluid flow through the potential waste emplacement area
to the accessible environment. This factor of the Yucca Mountain site is a further basis for
disqualification of the site from consideration for repository development.
10. Potential for Human Intrusion of Site

Potential for Future Human Intrusion of the Site
The greatest area of uncertainty in assessing the suitability of the Yucca Mountain site for a high-
level nuclear waste repository may be the potential for human intrusion of the site during
exploration for valuable natural resources. The EPA, NRC, and DOE in their regulations have all
recognized the issue and its inherent uncertainty by stating that geologic disposal sites should be
selected to avoid locations where resources have been mined, or where it is reasonable to expect
future exploration for valuable natural resources.
Nevada researchers have shown that "indicator" minerals suggesting the presence of precious
metals (eg. silver and gold) that could attract future exploration activities, such as drilling, are
found at Yucca Mountain. Trace amounts of these metals also have been detected in some
project core samples. This evidence suggests that the potential for valuable mineral resources in
the immediate vicinity of Yucca Mountain must be recognized along with the potential for
human intrusion and resultant repository disturbance.
The mining of base and precious metals has been important in Nevada's history and remains so at
present. Numerous Nevada ore deposits show common features, and many of these features exist
in the Yucca Mountain area. They include certain types of hydrothermal rock alteration and
distinctive geochemical signature minerals and suites of minerals. In addition, stratigraphic
studies show that the same volcanic tuffs that form Yucca Mountain have hosted significant gold
and silver production in the vicinity of Yucca Mountain. Some of these deposits were only
recently discovered and mined due to advances in exploration and extraction technology.
11. Yucca Will Cost $60-100 Billion

7. High Costs of Yucca Mountain:
$1.6 million per day is spent at the project, while little or nothing is spent to secure high-level
radioactive waste against accidents or terrorist attacks at the reactors across the USA where it is
currently stored in vulnerable indoor pools and outdoor dry storage casks. Yucca’s price tag
would be from $60 to over $100 billion of ratepayer and taxpayer money. Given that “only” $7
billion has been spent thus far, it’s high time to cut the losses before they become so much
worse!
12. Nuclear Fund Won’t Cover Costs

REPOSITORY PROGRAM COST AND REVENUES ARE OUT OF BALANCE
Any program with the scope, magnitude, and duration of the federal high-level nuclear waste
program, and especially one with the uncertainties of this first-of-a-kind undertaking, should be
continually evaluated as to its feasibility. Key to this evaluation is an analysis of the costs to
carry the program to completion and whether projected revenues are sufficient to meet the cost
of the program's implementation.
The Nuclear Waste Policy Act requires the DOE to "estimate, on an annual basis,...the costs
required to construct and operate the repositories to be needed...and to carry out any other
activities under this Act" and to "evaluate whether collection of the fee [authorized by the Act]
will provide sufficient revenues to offset the costs..." (Sections 301(a) and 302(a)). These
requirements are generally referred to as the analysis of "total system life cycle costs" (TSLCC)
and the Fee Adequacy Assessment.
During the nearly 16 years that the Nuclear Waste Policy Act has been in effect, DOE has
reported three times on projected costs and fee adequacy. The 1986 report estimated TSLCC for
a program, using a single repository in tuff at Yucca Mountain, to be $30 billion; the 1990
estimate was $33.5 billion; and the 1995 TSLCC reported an estimate of $34 billion (all in
constant 1996 dollars). In each instance, the 1 mil per kw fee collected from the users of
electricity generated by nuclear power plants was found to be adequate and not in need of
adjustment as provided for by the Act.
The State recently commissioned a cost and projected revenue estimate for the repository
program. It was intended to be a means of better understanding the financial implications of the
DOE's reference repository design, overall program plan, the recurring congressional bills that
would revise the Nuclear Waste Policy Act to provide federal centralized interim waste storage
at the Nevada Test Site beginning in 2003, and recent federal court rulings regarding DOE's
contractual obligation to begin accepting spent nuclear fuel from commercial reactors in 1998.
The report, titled "An Independent Cost Assessment of the Nation's High-Level Nuclear Waste
Program", February 1998, was prepared by independent analysts familiar with the program, and
includes a review of the analysis by a major national accounting and audit firm.
The total system life cycle cost, including previous repository program expenditures of $6.1
billion from FY 83 through FY 96, is estimated in this analysis to be $53.9 billion (in 1996
constant dollars). The components of this estimate of future costs for the described waste
management and disposal system include the following:
Onsite (at reactor) Storage: $4.3 billion (reimbursable costs due to delays in beginning waste
acceptance);
Cross-Country Transportation: $6.0 Billion;
Transportation in Nevada: $3.2 Billion (including rail line construction;
Centralized Storage Facility: $9.2 Billion;
Yucca Mountain Geologic Repository: $23.0 Billion;
Other Development and Evaluation Costs: $0.4 Billion;
Other Program Costs: $1.7 Billion.
The projected total program cost from FY 1997 through 2017 is $47.8 billion - $19.1 billion (or
66.8%) greater than DOE's estimate for the same period.
DOE's 1995 estimate of the total 1 mil per kw fee payments is that such payments will provide a
revenue base of $28.1 billion (in 1996 constant dollars). Therefore, at a total program cost of
$53.9 billion, the general taxpayer liability is $25.8 billion, or about half (48%) of the total
estimated program cost. In contrast, only about 10 percent of the waste planned for disposal in a
Yucca Mountain repository is considered a taxpayer responsibility, since it will be coming from
federally owned, rather than commercial facilities.
The implication of this cost-revenue analysis is that the cost of the program, even without
allowing for potentially costly uncertainties, and the liability for the general taxpayer are
substantially greater than have been previously estimated. And, the Nuclear Waste Fund under
its current fee structure will not meet its share of the program costs.
13. Yucca Does Not Meet DOE Siting Guidelines

The discovery of atmospheric nuclear bomb-pulse chlorine-36 in fracture coatings in and below
the Exploratory Studies Facility at the Yucca Mountain site has provided convincing evidence
that infiltrating fluid moves rapidly through fractures in Yucca Mountain from the ground
surface to the water table. This is in direct conflict with the DOE's original unsaturated zone flow
model and has caused the DOE to change its model from one depicting flow dominated by very
slow movement through the rock pores to one in which rapid fracture flow dominates. The State
has been advocating and developing such a model for a number of years and, as a result has
determined that the Yucca Mountain site cannot meet the groundwater travel time requirements
of the DOE's Part 960 siting guidelines and NRC's licensing rule, 10 CFR Part 60.
The Guidelines for site recommendation state: "A site shall be disqualified at any time during the
siting process if the evidence supports a finding by the DOE that a disqualifying condition exists
or the qualifying condition of any system or technical guideline cannot be met." 10 CFR Part
960.3-1-5.
The Post-Closure Geohydrology Disqualifying Condition states: "A site shall be disqualified if
the pre-waste emplacement ground-water travel time from the disturbed zone to the accessible
environment is expected to be less than 1,000 years along any pathway of likely and significant
radionuclide travel." 960.4-2-1. The Qualifying Condition states that the site must permit
compliance with the requirements of NRC's Part 60 licensing rule. The NRC's groundwater
travel time requirement is that "The pre-waste emplacement groundwater travel time along the
fastest path of likely radionuclide travel from the disturbed zone to the accessible environment
shall be at least 1,000 years or such other travel time as may be approved or specified by the
Commission." 10 CFR Part 60.113. The Commission has not approved or specified any
groundwater travel time requirement other than 1,000 years.
The chlorine-36 data indicate that the groundwater travel time through the fractured unsaturated
zone of Yucca Mountain can be as little as 50 years and probably much less from the
underground repository disturbed zone to the water table. The DOE total system performance
assessment agrees with the fast travel time and further acknowledges that the fractures are "likely
and significant" radionuclide pathways. An April 23, 1998 DOE presentation to the Nuclear
Waste Technical Review Board stated in regard to the unsaturated zone, "Long-term average
climate travel times are less than 1,000 years to the water table for unretarded [radionuclide]
species."
Travel time to the accessible environment in the saturated zone, once the infiltrating water
reaches the water table is also rapid. This travel time has been modeled for an accessible
environment boundary at a distance of 5 km from the disturbed zone (from the original EPA
standard, 40 CFR Part 191), and at 20 km (DOE's current interim standard). Using the longer 20
km (12 mile) distance, DOE's uncertainty analysis of its Total System Performance Assessment
(presented June 24, 1998 to the Nuclear Waste Technical Review Board) indicates that travel
time in the saturated zone can be as little as about 500 years.
State researchers also have modeled groundwater travel time in the saturated zone. Using what
they consider to be more realistic parameter values than those used by DOE for infiltration and
flux and using water temperature differences as an indicator of flow, they find the maximum 20
km ground water travel time in the saturated zone to be on the order of 100 years.
In either case, it is evident that groundwater travel time, as defined in the DOE's siting guidelines
and the NRC's repository licensing rule, is less than 1,000 years - a condition that requires that
the site be disqualified under DOE's site recommendation guidelines.
14. Quality Assurance Deficiencies


QUALITY ASSURANCE DEFICIENCIES
The issue of compliance with the NRC required Quality Assurance program for repository
licensing has plagued the DOE's Yucca Mountain project since its outset. The current NRC on-
site representative continually reports on the numerous quality assurance deficiencies in the site
characterization program, pointing out large amounts of unqualified, inaccurate, untraceable, and
suspect data being used to support technical assessments and conclusions about projected
repository system performance. He points out that much of the project data has been found to be
unacceptable and not usable in a license application, adding that the high Quality Assurance
deficiency rate has prevailed during the past 10 years of the Yucca Mountain site
characterization project with little or no improvement.
15. Container Lifetime, Radionuclide Dilution in Groundwater Untested


Projections of container lifetime and radionuclide dilution in the groundwater are largely based
on predictive models with little support from site data. This leads to large uncertainties. Recent
DOE presentations on total system performance assessment indicate that uncertainty in expected
peak doses resulting from uncertainty in waste package lifetime is greater than a factor of
10,000. The uncertainty factor in peak dose related to uncertainty in dilution ranges from 100 to
10,000.

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Nuclear Fuel Storage Counter Plan 1

2. Seismic Threats At Yucca

Impact: Water Under Yucca Used by Farming Community

Impact: Volcanism Would Release Massive Amounts of Radioactivity

Impact: Yucca Near Las Vegas, Los Angeles, Nellis AF Base

4. Containers for Transportation not Adequately Tested; Unsafe

Guidelines Re-Written Unsafely for YM:

5. Regulations Re-Written When Yucca Failed to Meet Standards

6. Politics Trumped Science in Opening Yucca

7. Regs Lowered Without Consideration for Population Risks

YM Doesn’t Provide for Geologic Waste Isolation:

8. Yucca Mountain Not Adequate for Long Term Geologic Isolation

9. Yucca Cannot Comply With Geologic Waste Isolation

10. Potential for Human Intrusion of Site

11. Yucca Will Cost $60-100 Billion

12. Nuclear Fund Won’t Cover Costs

13. Yucca Does Not Meet DOE Siting Guidelines

14. Quality Assurance Deficiencies

15. Container Lifetime, Radionuclide Dilution in Groundwater Untested

IEER NUCLEAR WASTE MANAGEMENT PLAN

The technology to accomplish HOSS is available.

The long-term repository plan should proceed as follows:

Ten years of the following scientific and engineering work:

Yucca Cannot hold more than 63,000 tons of waste

8. Yucca as “secure centralized storage” to prevent terrorism is a myth:

1. Yucca Mountain is an Earthquake Zone:

2. Seismic Threats at Yucca

Impact: Water Under Yucca Used by Farming Community

Impact: Volcanism Would Release Massive Amounts of Radioactivity

Impact: Yucca Near Las Vegas, Los Angeles, Nellis AF Base

5. Regulations Re-Written When Yucca Failed to Meet Standards

6. Politics Trumped Science in Opening Yucca

5. Politics trump science: corruption of the decision-making process:

7. Regs Lowered Without Consideration for Population Risks

( . . . “research findings generated as a result of Agency independent studies addressing key

CHANGING RULES AND STRATEGIES FOR THE YUCCA MOUNTAIN SITE

8. Yucca Mountain Not Adequate for Long Term Geologic Isolation

9. Yucca Cannot Comply With Geologic Waste Isolation

( . . . “research findings generated as a result of Agency independent studies addressing key

10. Potential for Human Intrusion of Site

( . . . “research findings generated as a result of Agency independent studies addressing key

Potential for Future Human Intrusion of the Site

11. Yucca Will Cost $60-100 Billion

7. High Costs of Yucca Mountain:

12. Nuclear Fund Won’t Cover Costs

( . . . “research findings generated as a result of Agency independent studies addressing key

REPOSITORY PROGRAM COST AND REVENUES ARE OUT OF BALANCE

Cross-Country Transportation: $6.0 Billion;

Transportation in Nevada: $3.2 Billion (including rail line construction;

Centralized Storage Facility: $9.2 Billion;

Yucca Mountain Geologic Repository: $23.0 Billion;

Other Development and Evaluation Costs: $0.4 Billion;

Other Program Costs: $1.7 Billion.

13. Yucca Does Not Meet DOE Siting Guidelines

( . . . “research findings generated as a result of Agency independent studies addressing key

14. Quality Assurance Deficiencies

( . . . “research findings generated as a result of Agency independent studies addressing key

QUALITY ASSURANCE DEFICIENCIES

15. Container Lifetime, Radionuclide Dilution in Groundwater Untested

( . . . “research findings generated as a result of Agency independent studies addressing key

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