Yucca Mountain: Time to Think the Unthinkable

by David Comarow, December 8, 2001

Testimony presented at U.S. Department of Energy Public Hearing


Two hundred and twenty-five years ago, we fought for and won our independence with muskets, one lead shot at a time. In the past couple of months, we have watched, in real-time, bunker-busting/cave-busting bombs penetrating the solid rock of mountains tens or hundreds of feet to blow up people and munitions.

We have come a long way in a very short time indeed. But 225 years is nothing regarding the slow transmutation of Uranium 235 to lead. The half-life of Uranium 235 is 704 million years. The half-life of plutonium 239, arguably the most toxic substance known to humankind, is 24,000 years. A billionth of an ounce of Plutonium will kill you if you inhale it. A piece of Plutonium, the size of a nickel, could kill a million people if adequately distributed.

Bunker-busting bombs. What a concept. When Yucca Mountain was first picked to “study” about 15 or 20 years ago, no one ever heard of “bunker-busting bombs.” It was unthinkable that someone could shoot an explosive-laden projectile into solid rock and concrete and have it blow up tens or even hundreds of yards within.

We have learned lately that many unthinkable things are only incomprehensible because we like to believe that all humans are rational and hold the same vital things.

What is unthinkable? That there might be, in the next, say 1000, 2000, 24000 years, a person who has the charisma and psychopathology of Osama bin Laden, Timothy McVeigh, Pol Pot, Adolph Hitler, Charlie Manson — all combined, and access to technology like bunker-busting bombs. What is unthinkable? — That they would use such technology to penetrate Yucca Mountain? Or that they could? Or that we couldn’t prevent it?

None of that is impossible, and therefore none of that is unthinkable. We are not talking about the short-term or even long-term economic prosperity of Las Vegas. We are talking about nothing less than the survival of the human race. Lest you dismiss this as just more fanatic hyperbole, let this be a reality check: Yucca Mountain will hold all of the high-level nuclear waste ever produced from every nuclear power plant in the U.S. – with about 10% additional defense waste — some 77,000 tons. The danger of getting it here aside for a moment, the amount of radioactivity and energy to be stored in one place, under that relatively tiny little bump in the desert, is quick enough to contaminate and sterilize the entire biosphere. Is that unthinkable? No. If it is possible, it is thinkable.

When discussing these types of risks, risks that can endanger entire segments of our population, let alone the whole earth, then the risk analysis must go into higher gear. It is not enough to merely calculate the risks as “extremely low” – because there is no “low enough” when the consequences are so explosive. For example, we accept certain risks, which are relatively high – 50,000 traffic deaths per year, But as terrible as those deaths and injuries are, they do not imperil our culture, nation, or the survival of the human race. We are less willing to accept such risks when the consequences happen simultaneously — plane crashes, for example. That is our human nature. We are eager to spend much more to lower the risk of death in groups than chronic deaths spread over time and space. As a people, as caretakers for future people, we cannot create unnecessary catastrophic risks like biosphereicide, the agonizing death of billions.

What will our present-day muskets–bunker-busting bombs, nuclear-tipped cruise missiles, and the like–what will they evolve into 225 years from now? 2000 years from now? 24000 years from now? Does anyone think this piece of rock will prevent the future Timothy Osama bin Hitlers of the world from making it their purpose to breach that fortress?

It is time we start thinking about the unthinkable because someone else is doing it too. Imagine the Timothy McVeighs of the future, flying practice bombing runs at the Nellis Test Range with more extensive, better-bunker-busting bombs. How’s this for a political statement?: Punch a hole in America’s most dangerous stockpile – the legacy of decades of the promise of nuclear power – “too cheap to meter.”


And what else is unthinkable? That Natural processes will breach the containment?

In several hundred thousand years, the waste at Yucca Mountain will still be deadly. Twenty-four thousand years ago, the Nevada test site was underwater. In 1992, a 7.4 magnitude earthquake in Landers, California, 190 miles from Yucca Mountain, caused water in a test well to rise 3.6 feet. Twenty-two hours later, a magnitude 5.6 earthquake at Little Skull Mountain, about 12 miles from Yucca Mountain, caused groundwater to rise 1.3 feet in one test well. Credible geologic studies from the University of Colorado and elsewhere suggest that the groundwater within Yucca Mountain has increased in the recent geologic past and could rise again.

Test wells in 1996 found elevated levels of Chlorine-36 more than 600 feet below Yucca Mountain. Where did that come from? Pacific Ocean nuclear tests held less than 50 years ago precipitated out of the atmosphere by rain and percolated into the ground. Rainwater passes through Yucca Mountain into the groundwater in a few decades. Unthinkable.

Yucca Mountain may look like the driest place on the earth. It is not. But no one has bothered looking anywhere else.

So what? Small amounts of water seeping into the containment vaults will corrode the vessels, eventually contaminating the groundwater. More significant amounts of water hitting the extremely hot nuclear waste would cause a cataclysmic explosion of expanding steam, resulting in a massive escape of radioactive materials into the atmosphere. At the very least, the radioactive plume would contaminate an entire swath of the United States, including the Midwest agricultural regions. Under the most unthinkable events, enough radioactive materials would vent into the atmosphere to deal the same fate to the human race that an asteroid did to the dinosaurs. If possible, it is thinkable, and such a risk is unacceptable when there is evidence of water under Yucca Mountain.


While theories of “autocatalytic criticality” caused by flooding have been widely rejected, new findings about the area’s geology may make this outlandish theory worthy of revisiting.

Regardless, flooding would not cause the Yucca Mountain stockpile to “go critical.” That’s when enough radioactive material is close enough to initiate a runaway nuclear chain reaction. A mere human bookkeeping error can cause it.

Unthinkable? Well, it has already happened. Not widely reported, a high-level nuclear dump in the former Soviet Union went critical, killing untold numbers and rendering a large area uninhabitable for centuries. The Japanese suffered a bad criticality accident in 1999. Although not nearly as catastrophic as the Russian disaster, it contaminated 49 people and raised radiation levels 15,000 times above the background. According to France’s nuclear safety institute DSIN, the Tokai, Japan accident was the 60th criticality accident since 1945, 33 of which occurred in the United States and 19 in the former Soviet Union. Thankfully, most of these accidents were in laboratories and thus small-scale, but maybe such an accident isn’t unthinkable.

A mere human error in keeping track of the frantic precise placement of some 10,000 containers of high-level waste could lead to nuclear criticality – the dirtiest fission explosion ever. It could be the last bookkeeping error humanity ever made.


Is it unthinkable that a tractor-trailer – one of at least 6,000 truckloads (some say as many as 100,000 truckloads) and at least 9,000 rail shipments through 43 to 46 states over 30 years – would be hit by, say, a fuel tanker on a bridge, in heavy fog, and plunge 100 feet onto another fuel tanker than then be hit by a tractor-trailer carrying steel? By DOE’s estimates, these nuclear waste trucks will be involved in around 300 accidents.

Is it unthinkable that someone, domestic or of foreign brew, would target one of these shipments for destruction or theft? We are told how safe the casks are. But that assumes lots of things. The mujahedeen can blow up tanks with shoulder-fired weapons. Does anyone think these unarmored tractor-trailers in traffic on I80 or train cars behind the last Amtrak are safe?

As recently as 1989, there was a bad Southern Pacific Rail Road accident. Six locomotives pulling 69 cars loaded with potash lost their brakes and descended a 2.2% grade for 23 miles. Its speed exceeded the 90 mph maximum ability of the black box recorder. Two people on the train and two children in track-side homes were killed outright. Eleven people were injured. Then more unthinkable — two weeks later, the petroleum pipeline paralleling the tracks exploded due to the damage it incurred in the accident. Two more people were killed.

The suitability report does not adequately consider the inevitable confluence of factors – the bad luck that seems to pile up when things go wrong—for example, a natural gas pipeline at the crash site.

September 11, 2001, changed a lot of thinking. At the very least, it reminded us that the unthinkable is not only thinkable; when it comes to this potential doomsday cache, we must assume it is inevitable. We cannot think in terms of just years or decades. We cannot think of just Las Vegas or even just America. We are the stewards of over 77,000 tons of highly radioactive death we created. We could argue whether or not we should have, but that isn’t relevant right now. It is enough to recognize and accept that we cannot let the momentum of the desire to sweep this under the rug or the attractiveness of short-term political gain allow us to forge unthinkingly ahead.


Since the Manhattan Project, the nuclear community has told us that we can engineer perfect safety in all phases of the life cycle of nuclear materials. The best minds in the best labs tell us we can create safe atomic power plants, safe transportation systems, safe fuel processing, and safe permanent disposal. The best minds in the best labs also bundled the primary and backup control cabling together at Brown Ferry. It burned when a technician checked for air leaks using a candle, almost leading to a catastrophic melt-down – prevented only by pure luck – the use of pumps not intended for emergencies. The best minds forgot that humans can make mistakes – like at Three Mile Island. And the best minds never wanted to believe 15 hijackers could simultaneously take over four airliners and drive them into skyscrapers and the Pentagon. The best reasons are simply no match for what some of us call the “5th Law of Thermodynamics” (Murphy’s Law) – “What can go wrong will go wrong.” The best minds do not think the unthinkable because our humanity gets in the way.

These hearings are viewed by many, maybe most, as a meaningless exercise. I hope that is wrong because that would also be unthinkable.

It is time to rethink. Are there alternatives? Certainly. Have we studied them in detail? No. Why not? Is everyone in the DOE so intelligent and infallible that they already know the best solution?

The Department of Energy (DOE) and the Nuclear Regulatory Commission (NRC) are the remnants of the Atomic Energy Commission (AEC), which had the dual, conflicting roles of promoting and regulating nuclear energy. From what I have seen, the old culture lingers. The fundamental, inherent conflict of interest still pervades both agencies, each trying, certainly pressured, to sweep the waste part of the nuclear cycle under the rug – out of sight, out of mind, bury it under Yucca Mountain. I hope September 11, 2001, changed that – because much of what was unthinkable is now live on CNN.

For those who say that continuing to store waste at nuclear power plants is not acceptable, I agree. But, for the time being, with improved safeguards, it is a far better short-term solution than running thousands of trucks and trains a year through America’s heartland ladened with spent fuel rods. We must be SURE the final solution is the safest, not the quickest. At least ten nuclear power plants have already converted to safer dry storage. More can be done to take the time pressure off finding the best permanent solution.

The Yucca Mountain study is bad science. Worse, it is corrupted science. Any science that begins with a pre-ordained conclusion is not science at all – it is politics cloaked in the appearance of science. The study contains so many biased and flawed fundamental assumptions that, for the most part, it isn’t worth the reams of paper it is printed on. The entire proposed disposal cycle is fatally flawed. We need to look at other alternatives – and there are many.

Maybe all the waste ought not to be put in one place. Perhaps, sweeping it under the rug by putting it in one of the most geologically-active places in the U.S. isn’t such a good idea. A volcano nearby erupted only 10,000 years ago. That is just a moment in geologic time. The earth’s crust in the area is stretching at a rate much higher than predicted -about a millimeter a year, according to a Cal Tech study. That’s 10 meters over the 10000-year design life.

Maybe the waste should be embedded in the glass. Perhaps it should be subject to transmutation processing. Maybe, as a Woods Hole Oceanographic Institute scientist suggested, it ought to be injected deep into the most geologically-stable place on earth – the Silly Putty-like clay sediments three miles below the North Pacific – stuff that has been completely stable for 65 million years. Maybe. I don’t know, but this is not the place to decide on alternatives – it is enough to know that many haven’t been objectively or thoroughly studied – mainly for political reasons. The DOE perfunctorily dismisses the other options because, it says, deep geologic disposal is the best. Period. End of discussion. Even if they are correct, the question is: is Yucca Mountain the best deep geologic disposal site? We will never know if we do not study other sites.

It is time to stop, take a collective breath, and do the right thing. The Yucca Mountain project ought to be put out of its misery. God bless America. And God help us all if this project proceeds.

(c) 2001 David Comarow, Esq. This material may be freely reproduced and distributed so long as it remains complete and unedited. Any other use without written permission is prohibited. All rights reserved.