From the Stop I-3 Coalition
C/o John M. Clarke, Board Member
Hayesville, NC 28904
January 12, 2007
Mr Theodore A. Wyka
Complex 2030 SEIS Document Manager
Office of Transformation
US Dept of Energy, NA-10.1
1000 Independence Ave SW
Washington, DC 20585
Re: EIS Comment, Complex 2030
Dear Mr Wyka:
The Stop I-3 Coalition would like to make the following points and pose the following questions regarding the Department of Energy/ National Nuclear Security Administration plans for Complex 2030, which involves significantly increasing nuclear weapons activities at Oak Ridge, TN and Savannah River Site, SC, with accompanying nuclear materials transport on the highways of the Southeast region. This is the final version of our comment for the Complex 2030 EIS scoping phase and should replace the preliminary statement we filed at Oak Ridge, Tennessee on Nov 13, 2006.
The Stop I-3 Coalition was formed in 2005 in response to the inclusion in the 2005 Highway Bill (SAFETEA-LU sec 1927), of a study of a proposed highway variously known as Interstate 3 or The Third Infantry Division Highway. It would connect Savannah, Augusta, and Knoxville with an interstate highway routed through North Georgia, possibly South Carolina, Western North Carolina, and East Tennessee. The mission of the Stop I-3 Coalition is to preserve the integrity of our communities, mountains, lakes, streams, and forests by preventing the construction of I-3 or any similar highway in the Southern Appalachian and Piedmont Region.
Our interest in nuclear matters stems from the fact that the proposed highway would connect the Y-12 Plant at Oak Ridge with the Savannah River Site in the Augusta area and the Port of Savannah. We have noted with concern that the I-3 proposal coincides with a considerable effort on the part of the government and a number of utility companies to increase nuclear weapons programs and nuclear power activities, including waste reprocessing, and the concentration of these activities in the Southeast. We are convinced that should I-3 ever be built it would become a convenient route for the traffic in radioactive materials which would arise from Complex 2030 and the Global Nuclear Energy Partnership, as well as expected routing of nuclear wastes and plutonium through the area. This is not acceptable to us or to the coalition of citizens and groups we represent (please see http://www.stopi-3.org/members.html for a list of our supporting organizations). As a coalition, we are not an antinuclear group, but it has been our policy since our formation to research issues related to the possible construction of Interstate 3, including nuclear transport activities in the region.
As our comment on the Complex 2030 Environmental Impact Statement, we offer the following questions and comments. We have also invited those on our mailing list to submit individual comments of their own.
Has the Dept of Energy or its contractors been a party to the proposal to build Interstate 3? Are there any classified or unclassified documents in existence where DOE or NNSA has included I-3 in its planning for nuclear transport?
Would the nuclear transport necessitated by Complex 2030 take place on Interstate 3 if it is ever built? What other routes would be taken by trucks hauling uranium, plutonium, and tritium through the region? Will there be international traffic in these materials through the Port of Savannah as part of Complex 2030 or other DOE programs? What volume (how many tons, how many truckloads or rail car loads) of radioactive cargo would be generated by the implementation of Complex 2030? Will detailed information on the nuclear transport necessitated by Complex 2030 be included in the EIS?
What possible guarantees can the DOE or NNSA offer that all this nuclear transport could be done safely? Would the trucks be marked as containing radioactive cargo? Would local law enforcement and emergency personnel be notified of the shipments? Would the DOE and NNSA be capable of conducting cleanup, public safety operations, or environmental damage containment in the event of a spill, accident, or sabotage? What hospitals along the route would be capable of administering treatment to residents and travelers who may be exposed to radiation?
We understand that even when no notable incidents occur, the process of nuclear materials transport exposes drivers and the public to varying levels of radiation exposure. In the event of a spill or accident, this exposure could become catastrophic, causing thousands of deaths and cancers and potentially rendering uninhabitable large tracts of land. Will the EIS take into account the risk of this kind of event occurring?
Should not the total picture of nuclear transport and its attendant hazards be included in the EIS for Complex 2030? We submit that it should and we will not regard as complete any EIS which ignores the impact of nuclear transport on the environment and the people of our region. It is our hope that the final EIS will address the questions raised above and treat transport between facilities as an integral part of the Complex 2030 proposals.