Draft
YUCCA MOUNTAIN PROJECT
PUBLIC COMMENTS to the US Department of Energy
Site Recommendation (SR) and Environmental Impact Statement (EIS)
From: D. Opaneye
Resident of Las Vegas, Nevada
Contact Info: Yucca-Mountain-Project-Discussion-
Group@Yahoogroups.com

When I first heard about the Yucca Mountain Project I had
been a resident of Las Vegas for over a year. I was initially quite
excited about the extraordinary possibilities: Science applied to
solving a problem on a massive-scale, combining disciplines as
diverse as and including Physics, Bio-physics, Geology, Engineering,
and Computer Technology; Dedicated staff from all over the globe
working together; The negotiated benefits to residents and
businesses in the immediate vicinity of Yucca Mountain; and
a "Nuclear Culture" emphasizing strict adherence to checks and
balances, "Lessons Learned" and accountability from the top down.
From my enthusiastic starting-point it has been a long and
disappointing trip to where I am now regarding the Yucca Mountain
Project: I am certain that this Project will end in disaster, loss
of life, disruption of the local economy, and permanent damage to the
environment on a scale never dreamt of. I am certain that it is only
a question of when and how often: Soon after the shipments of
nuclear waste from around the country begin? In my lifetime? In my
children's lifetime? Or hundreds of years from now.

1. The best staff who have worked on the Project (by best I mean
those professionals who have the most integrity and expertise and
common sense) have left the Project and it is expected that more of
the same will follow. I urge the DOE, the SR teams, the EPA, and
local government to locate high-level staff who have left the
project, create an interviewing and questionnaire strategy designed
to elicit truths from people who are understandably reluctant to say
for the record exactly what they have been saying behind closed
doors, and study the results before recommending Yucca Mountain as
the nation's nuclear waste repository.

2. The only direction taken in the official Yucca Mountain Project
has been toward recommending Yucca Mountain. Because of the hazards
involved in transporting and storing High-Level Waste (HLW), I am
certain that this has been the wrong approach. The real money
(billions of dollars so far), staff hours, and other resources,
should have been directed toward studying why Yucca Mountain should
not be the nation's nuclear waste repository. Only with a "should
not" focus can all potential hazards be adequately studied. With
a "should" focus, the politicians of states who have nuclear waste to
get rid of, the government, the politicians of states who don't want
nuclear waste stored in their own backyards, and the nuclear waste
itself, are given the benefit of the doubt. Only with a "should not"
focus can the local residents, businesses and environment that will
be the most-severely affected, be given the benefit of the doubt.

3. Staff working on the Project, especially the highest-level staff
and scientists, have been imported to Nevada from across the country
and even from across the world. When their roles in the Project are
completed, they will pack up and leave town. When TRW lost its
contract on the Yucca Mountain Project, there was a massive migration
out of Nevada. Most of the staff working on the Project know that
whatever happens to Nevada as a result of the Yucca Mountain Project,
it will not affect them, their homes, their families, or their
future. They won't be here. It is impossible to trust the work and
recommendations of people who have no vested interest in the outcome,
who are here to do a job for a little while, collect a paycheck, then
pick up their families, sell their homes (or terminate their
apartment leases) and leave.

4. I have observed that the least complicated, most easily-
achievable aspects of working on the Project are consistently
mishandled, and we haven't even begun to transport waste across the
country, store waste in Yucca Mountain, or monitor environmental
impact as waste is transported and stored. Logic suggests that if
the Project is unable to manage the simplest aspects of this
endeavor, the most complicated aspects which will have the most
severe effect on lives, businesses and the environment, are beyond
the abilities of the DOE and the subcontractors it chooses to work on
the Project.

5. I have observed on the Project that when a problem is discovered,
it is likely to go ignored for some time and possibly never
addressed. If it is addressed, even when all are in agreement that
the problem exists and needs to be resolved, the resolution will be a
long way off. If a resolution is decided upon, it will be some time
before the resolution is implemented. If a resolution is
implemented, it is implemented only half-way. If anyone cares enough
to monitor the implementation and demand a complete resolution, it is
likely to be a lone individual who has the integrity to stick his or
her neck out, because monitoring a situation and making repeated
demands cannot be done anonymously. I have observed this at every
level of the Project. I cannot feel safe or confident that this
pattern will magically change if the Project moves from Site
Recommendation to Site Construction to Waste Acceptance. Again, and
I cannot emphasize this enough, logic suggests that if the Project is
unable to manage the simplest aspects of this endeavor, the most
complicated aspects which will have the most severe effect on lives,
businesses and the environment, are beyond the abilities of the DOE
and the subcontractors it chooses to work on the Project.

6. The "OCRWM Concerns" program is considered by many staff to be a
joke. It is considered to be, at best, window-dressing.

7. The NWTRB does not have the daily hands-on Project experience and
context to be a reliable part of a checks-and-balances system. While
the NWTRB's heart is apparently in the right place, the NWTRB itself
is not in the right place. A well-funded scientific checks-and-
balances system needs to be working on the Project daily, here in
Nevada, side-by-side with the DOE and it's subcontractors.

8. Managers of Project departments are making decisions based on
budget, deadline, and office-politics priorities instead of quality-
control priorities.

I have observed on the Project that when a serious problem is
noticed/identified, even if that problem becomes well-known among
staff and management, if there is no written "Procedure" requiring
resolution of that problem, the problem will be ignored. Again,
budget, deadlines and office-politics will be the priority
considerations whenever problems are noticed/identified/foreseen.
Project staff has learned to address problems in this manner, and it
will in fact be difficult for staff to unlearn this approach. It
would require specific and deliberate rewiring of the current Project-
wide mind-set. The term "Nuclear Culture" is used on the Project.
It's supposed to refer to high standards. The "Nuclear Culture" I
have observed, however, can definitely be seen as a "culture" yes,
but the culture then has to be studied to determine what it's values
are. In this case, what can the public expect from the "Nuclear
Culture" as it actually exists on the Project? It doesn't take much
imagination to recognize the potential for loss of life, destruction
of property, and destruction to the environment, that can result from
the type of ingrained, habitual approach ("cultural" approach) to
known problems once the Project moves from Site Recommendation to
Site Construction to Waste Acceptance.

It is my understanding that the US Department of Energy is currently
accepting Public Comments about the Yucca Mountain Project. I am
thoroughly convinced that these Public Comments will be basically
ignored and/or given lip service. Nevertheless, I do feel a
responsibility to attempt to appeal to any of the reason, ethics,
honesty, concern for life, and concern for the environment, that may
be left among the decisionmakers involved in the Yucca Mountain
Project.

D. Opaneye
Resident of Las Vegas, Nevada
Yucca-Mountain-Project-Discussion-Group@Yahoogroups.com