ML20195H519

Declaration of J Catlin for Petitioner Southern Utah Wilderness Alliance (Suwa).* Declaration Discusses 1998 Reinventory of Bureau of Land Management Wilderness Lands. Notice of Appearance for Re Condit & J Walker Encl

ML20195H519
Person / Time
Site:	07200022
Issue date:	11/18/1998
From:	Catlin J SOUTHERN UTAH WILDERNESS ALLIANCE
To:
Shared Package
ML20195H508	List: ML20195H503 ML20195H519
References
ISFSI, NUDOCS 9811240017
Download: ML20195H519 (10)

Text

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Private Fuel Storage, a Limited Liability Company; Docket No. 72-22 November 18,1998 (Independent Spent Fuel Storage Installation).

DECLARATION OF JIM CATLIN FOR PETITIONER SOUTHERN UTAH WILDERNESS ALLIANCE (SUWA)

I, Jim Catlin, based on personal knowledge, declare as fullows:

l A. Background

1. I am an adult citizen and resident of Salt Lake County, Utah. I was raised in Utah and i

have lived there almost all of my life.

2. I have a PhD from the University of California, Berkeley in Natural Resource Management and Geographic Information Systems (GIS). I have been practicing in this field for 20 years.

3. I am a member in good standing of the Southern Utah Wilderness Alliance (SUWA),

petitioner in this matter, and was one of the original members of the organization.

4. I am project director of the Wild Utah Project. Like SUWA, the Wild Utah Project is i

a key member of the Utah Wilderness Coalition (UWC) and supporter of the 1998 reinventory of

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Bureau of Land Management (BLM) wilderness lands. The gaal of this reinventwy effort was to: 1) obtain thorough, accurate data to establish which BLM lands qualified for wilderness I

designation; 2) exclude areas that ose, but no longer, qualified as wilderness; and 3) insure that i

f any resulting wilderness proposal fuiiy represented Utah's biological richness and geographic diversity. SUWA, who is a board member of UWC, spear-headed and was collectively in charge

. of the reinventory process, along with other UWC Board members.

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5. I participated in the original inventory of BLM lands for SUWA which resulted in the Citizens' Wilderness Proposal. This proposal is the basis for legislation currently pending in the United States House of Representatives (H.R.1500) and the Senate (S. 773), which would protect all the lands in the proposal under the Wilderness Act of 1964. This legislation now has approximately 147 co-sponsors among House and Senate members.

6. I, together with my staff members, created the map entitled "The Impacts of the Low Rail Spur on the North Cedar Mountains Roadless Area" attached to SUWA's Petition as Exhibit

2. To make this map I overlayed wilderness boundaries that we created based on field data on top of other digital map information from state and federal agencies. I then added digitized information from the map included in the license amendment indicating the alignment of the proposed Low Rail Spur.

7. I am intimately familiar with the criteria used by various public land agencies, including the BLM, to determine which lands are suitable for wilderness. I have extensive practice in making such determinations on the basis of field work, maps, aerial and ground photographs and other information.

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B. The Reinventory Process 8.1I am under contract with UWC and am working in close cooperation with SUWA to complete the reinventory process of BLM lands for wilderness character. I am a member of the

- technical :eview team (TRT) which ultimately proposed to SUWA and the UWC lands deserving Lwilderness protection.

9. To conduct'this reinventory, we relied on standards that have been established by

-. Congress and federal land management agencies for determining which lands should be

~ designated as wilderness pursuant to the Wilderness Act of 1964. These statutes and regulations

provide definitions of"roadlessness," "substantially unnoticeable" impacts and other criteria necessary for determining the wilderness character of particular lands pursuant to the Wilderness Act. Essentially, large tracts of roadless public lands, where human impacts are substantially unnoticeable, qualify for wilderness designation and must be determined as such by the BLM.

10. With these criteria as a basis and with guidance from SUWA and the UWC, we

' conducted our reinventory field work in several stages. Prior to the actual field work, we gathered as much information as possible about each large potential wilderness area. On average, we put in at least ten hours of work per potential wilderness area, creating maps for use in the a

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' field. We modified United States Geological Survey (USGS) 7.5 minute scale maps with land ownership information, cross-checked with BLM's land status plats. We then consulted recent aerial photographs of the area to locate impacts not already on the USGS maps. Aerial maps

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. proved to' be 'a very reliable indicators ofimpacts, which, in a fragile desert environment, are

- easily identified from above.

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11. Next, carefully screened and trained volunteers and staff conducted field work to verify map information. These volunteers received approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of training in the p,

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classroom, in sessions run by me and other staff members. Then; each volunteer was trained by l

~ me or other staff members in the field for approximately one half day. Next, the volunteers were l

assigned a potential' wilderness area and given a packet contaimng several maps, film, i

l instructions and forms for field notes.

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12. Field workers then traveled the outer boundary of each potential wilderness area, i

' taking frequent photographs of impacts to the land. These workers traveled the length of any

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h intrusions (and any branches ofintrudons) entering into a roadless area.. Any impacts were photographed and these photographs linked to maps. As a result of this work, each roadless area l

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- was further documented by field notes and photographs (40,000 'to 50,000 photographs in all).

13. I, together with other staff members reviewed all volunteer work. If we discovered gaps.or inconsistencies in the field work,1 or other staff members would revisit the site, several l

times, if necessary, to complete field checks. We also gathered additional information, including ;

off-road vehicle routes, mineral deposits and grazing uses. On the basis of maps, field work and

-any additional 'in' formation, we m5de a preliminary boundary recommendation. This recommendation was, in turn, reviewed and fine-tuned by the technical review team (TRT), of which I was'a member. The four members of the TRT critiqued all preliminary l

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- re, commendations for consistency and integrity. The TRT adopted stricter wilderness 7

Iidentification guidelines than the BLM so that the resulting boundaries would be above L

F (challenge. The boundary specifications that resulted from TRT review were then digitized on -

GIS along with a written detailed description of the boundary, together with rationales for any n

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tough decisions involved.

14. Because one of the goals of the 1998 inventory process was to use wilderness l

designation as a means to protect biological diversity, Wilderness Act,16 U.S.C.A.

I131(3)(4),

f the TRT, in consultation with biologists, gave priority to areas containing large elevation t

gradients, large complexes on contiguous roadless areas, and riparian areas.

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15. The inventory of the North Cedar Mountains roadless area was conducted according to this standard procedure. Inventory staff spent approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> preparing maps for l

field survey work,'which included review of aerial photographs. The area was then surveyed by a volunteer who took field notes describing each of the 24 pictures linked to USGS maps. Then L

inventory staff members (one of whom was a member of the TRT) revisited the site and took 38 more photographs, which were also described in field notes and linked to maps. Then I, together i

with other TRT members, used this information to recommended the boundaries of the proposed wilderness area to SUWA and the UWC, This consultation resulted in the proposed wilderness designations as are depicted on the North Cedar Mountains Map.

l C. Impacts of the Low Rail Spur on the North Cedar Mountains.

16. The construction and operation of the Low Rail Spur and the construction and maintenance of the fire buffer zone will irreversibly impair the wilderness character of the North l

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Cedar Mountains.

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17. If constructed pursuant to the license amendment, the Low Rail Spur will significantly intrude into the North Cedar Mountain roadless area so that it will no longer be an i

L area which " generally appears to have been affected primarily by the forces of nature, with the imprint of[ human] work substantially unnoticeable:..." Wilderness Act,16 U.S.C.A. G

l I 131(c)(1). In addition, the operation of the rail spur will significantly intrude upon the area's currently " outstanding opportunities for solitude...." R, 1131(c)(2). Finally, the construction and operation of the rail spur will have adverse impacts on the area's wildlife and plant life values which are essential to the ecological health of the area. E, @ l131(c)(4).

D. Standing

18. Members of SUWA use and enjoy the waters, p6blic lands, and natural resources on BLM lands for many health, recreational, scientific, spiritual, educational, aesthetic, and other purposes. SUWA members enjoy hiking, camping, birdwatching, study, contemplation, solitude, photography, and other activities in and around the public lands ever which the Low Rail Spur will traverse. SUWA and its members also participate in information gathering and dissemination, education and public outreach, commenting upon proposed government actions, and other activities relating to the management of and impacts on BLM lands, including the North Cedar Mountains and other public lands and resources in the area managed by the BLM.

These health, recreational, scientific, spiritual, educational, aesthetic, informational, and other 1

interests will be directly effected and irreparably harmed by a decision to allow construction and operation of the Low Rail Spur, and by other agency actions which may impact the North Cedar Mountains or any other roadless BLM lands.

19. In aC lition, SUWA is actively involved in citizen oversight, review and comment upon governmerz iecision making affecting BLM public lands. The government's potential failure to disclose critical environmental effects of the proposed rail spur in its analysis and decision-rnaking documents may harm SUWA's ability to fulfill their organizational mission to inform SUWA members and others about threats to the environment. i-l-

20. I have used and enjoyed the public lands and natural resources on BLM lands for r

i many health, recreational, scientific, spiritual, educational, aesthetic, and other purposes and have used and enjoyed for these same purposes, the exact tract oflands contained in the North Cedar l

Mountains roadless area as depicted in Exhibit 2. My health, recreational, scientific, spiritual,

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' educational, aesthetic, informational, and other interests will be directly effected and irreparably -

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l harmed by a decision to allow construction and operation of the Low Rail Spur and by other i

l agency actions whien may impact the North Cedar Mountalie, or any other roadless BLM lands.

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21. The North Cedar Mountains roadless area possesses wilderness character and sliould -

f-be designated as wilderness. I will be harmed if the Low Rail Spur is constructed and operated.

I This construction and operation will eliminate the North Cedar Mountains from consideration as

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wilderness and will prevent these lands from receiving the increased management protection given to wilderness areas. In addition, the construction and operation of the Low Rail Spur will.

threaten the ecological values of the North Cedar Mountains. If these values are harmed, I too

- will be harmed.

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- I DECLARE, under penalty of perjury, that the foregoing is true and correct.

Executed on this November 18,1998 JIM CATLIN f

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20. I havc uisd Lad enjoyed the public lands t.nd natural resources on BLM lands for nway 1.ulth, cacreadon4, scientific, spirituni, edticational, resthetic, and other purposes and have used and en,:oyed for these same purposes, the er.act tr :t of1:nds ec. tait:ed in the Nuitli Cedu Motmtams read!es. arca na depicted sa A' liibis 2. My heaitn, recreationru, scientific, spm:ual, educational, aestnetic, mtormational, and other mterests will be directly effected and irn:pm ably harmed by a decision to allow constniction mod operation of the Low Rail Sp= and by o$:r egency actions which may impact 1: Ncrth Ceda: Mouniams or any other roadless BLM iancs.

21. The North Cedar Mountains roadjess area possesses wildemess character r.nd should

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be designated as wildemess. I will be harrned if the Low Rail Spm is cons: meted :nd ep:=::d.

I This construction and operatica.,-!! climinatc the North Ccdm M6mtains from consideranon as wilderness and will prevent these lands from receiving 6 ins!: ted management pro ::t:: 7.

giver. te wddenxu, raeas in addition, the construction and operation ot'the Low Rail Spur will drcsteu 11.2 ecological v4]ue3 uithe North Cedar Mountains. If these values are harmed,.I too will bc harned 1

I DECL ARE, ut. der pens!!y of p::jur, t'.at i-for:;,0in;; as tr.;; and ccrrect.

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Er.e:uted en tis Nev:=ber 18,199B NM T. AT 1.IN e

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w UNITED STATES OF AMERICA DOCKETED-NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 96 NOV 23 P4 :12 OFFl"Uid.T " m: b f ' '

Rd Private Fuel Storage, a Limited i

Liability Company; Docket No. 72-22 ISFSI ADJUU.C/+0 ',

WFF (Independent Spent Fuel Storage Installation).

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorneys enter their appearance on this 18'h day of November,1998 in the above captioned matter. In accordance with 10 C.F.R. 2.713(b),

i the following information is provided:

Name:

Richard E. Condit Address:

Land and Water Fund of the Rockies 2260 Baseline Road, Suite 200 Boulder, Colorado 80302 E-mail:

rcondit@lawfund.org Telephone:

303.444.1188 ext. 219 Telefax:

303.786.8054 Admissions:~

United States Supreme Court United States Courts of Appeals for the D.C.,4th, 5th gth, and 10'" Circuits United States District Court for the District of Columbia, District of Colorado, and S.D. Indiana District of Columbia Courts (Bar No. 417786) i-Name:

Joro Walker Address:

Land and Water Fund of the Rockies 165 South Main, Suite 1 Salt Lake City, Utah 84111 1

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e E-mail:

joro61@inconnect.com Telephone:

801.355.4545 Telefax:

801.579.3324 Admissions:

Utah State Bar (USB # 6676)

United States District Court for the District of Utah Tenth Judicial Circuit Court of Appeals Name of Party:

Southern Utah Wilderness Alliance (SUWA)

Respectfully submitted,

/s /

Richard E. Condit

/s/:

Joro Walker -

Counsel for Southern Utah Wilderness Alliance i

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00CKETED USHRC UNITED STATES OF AMERICA BEFORE THE

% O 23 37 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA

'Y:

g)juDi '

'F Private Fuel Storage, a Limited Liability Company; Docket No. 72-22 November 18,1998 (Independent Spent Fuel Storage Installation).

SOUTHERN UTAH WILDERNESS ALLIANCE'S CONTENTIONS REGARDING PRIVATE FUEL STORAGE FACILITY LICENSE APPLICATION (THE LOW RAIL SPUR).

Pursuant to 10 C.F.R. f 2.714, the Southem Utah Wilderness Alliance (SUWA) hereby submits its contentions regarding the amendment to the license application of Private Fuel Storage ("PFS") to operate a nuclear fuel storage facility on the Skull Valley Goshute Indian Reservation in Tooele County, Utah. SUWA is filing, with this statement ofits contentions, a petition for intervention and request for hearing, which, along with the attachments to that I

document, SUWA hereby incorporates and references.

SUWA's petition and request establish that SUWA should be allowed to fully participate in this proceeding with regard to assessment of and decision-making involving the alignment, construction and operation of the Low Rail Spur and the construction and maintenance of any associated impacts such as the fire buffer zone.

As documented below, the applicant PFS has not complied with the required standards established for licensing a nuclear fuel storage facility. In fact, PFS's license application is 1

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substantially incomplete. SUWA therefore respectfully submits that this license application should be denied.

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CONTENTION A:

Statement: The License Application Amendment fails to consider adequately the 1

i impacts of the Low Corridor Rail Spur and the associated fire buffer zone on the wildemess character and the potential wilderness designation of a tract of roadless Bureau of Land Management (BLM) land - the North Cedar Mountains -- which it crosses. SUWA has determined, afte'r significant analysis, that the North Cedar Mountains qualifies for and should be designated as wilderness under the Wilderness Act of 1964 and therefore should be preserved in its current natural state until the United States Congress has an opportunity to evaluate the land for wilderness designation.

Basis: PFS's amendment to its license application includes, inter alia, as a preferred option, construction and operation of the Low Rail Spur and the associated fire buffer zone, i

PFS intends to use the Low Rail Spur to transport high level nuclear waste from the Union Pacific main rail line at Low Junction to the Skull Valley Reservation. License Application Amendment, August 28,1998 (" Amendment").

The Low Rail Spur will traverse approximately 32 miles of undeveloped public lands afministered by the Bureau of Land Management (BLM) including the North Cedar Mountains, i

an outstanding natural area identified by SUWA as possessing wilderness character and therefore suitable for wilderness designation and protection under the Wilderness Act of 1964. The Low Rail Spur will entail construction of a right of way of 250 feet on each side of the railroad center-l i

- line, Amendment at Figure J.5-6, Sheet 1, and " clearing and grubbing activities for a width of P

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l-l approximately 50-ft."E at 3.2.1.5. Furthermore,"[t]o reduce the potential for increased range fires that may be caused by rail transport, the 40 ft wide rail spur corridor will be cleared of vegetation...." E at 4.4-9.

SUWA included the North Cedar Mountains in its 1998 Citizens' Wildemess Reinventory, which specifies all the BLM lands in Utah that qualify as wilderness. SUWA has

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widely publicized the results of the reinventory to the public. The event generated a great deal of media coverage and was taken seriously by the govermnent and the public. Further, SUWA and the Utah Wilderness Coalition (UWC) will attempt to educate members of Congress about Utah's wilderness areas and support the passage of federal legislation that will designate all the j

1 lands in the 1998 reinventory as wilderness. Until then, SUWA will take all necessary steps to l

preserve these lands, including the North Cedar Mountains, in their current state and to protect them from any development or other impacts which would disqualify them for wilderness l

designation. See, SUWA's petition and request.

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The inventory of the North Cedar Mountains area was conducted according to a rigorous and informed procedure. Inventory staff spent approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, including review of aerial photographs, preparing maps for field survey work. The area was then surveyed by a volunteer who took field notes describing each of 24 pictures which were also linked to USGS maps. Inventory staff members revisited the site and took 38 more photographs, described in field notes and linked to maps. The technical review team then used this information to determine the boundaries of the proposed wilde'rness area depicted on Exhibit "2", attached to l

SUWA's petition and request. See, also, Affidavit of Jim Catlin.

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As the description of the proposed project indicates, the construction and. operation of.the l

Low Rail Spur and the clearing of the fire buffer zone will irreversibly impair the wilderness character of the North Cedar Mountains. See, Affidavit of Jim Catlin, attached as Exhibit "3" to SUWA petition and request. If constructed pursuant to the PFS amendment, the Low Rail Spur will significantly intrude into the North Cedar Mountain roadless area so that it will no longer be i-an area which " generally appears to have been affected primarily by the forces of nature, with the imprint of[ human] work substantially annoticeable;..." Wilderness Act,16 U.S.C.A.

I 131(c)(1). In addition, the operation of the rail spur will significantly intrude upon the areas currently " outstanding opportunities for solitude.. " M, 1131(c)(2) Finally,the construction and operation of the rail spur will have adverse impacts on the area's wildlife and plant life, values which are essential to the ecological health of the area. M, 1131(c)(4). See, Affidavit of Jim Catlin.

Despite the wilderness character of the North Cedar Mountains and its potential designation as wilderness pursuant to the Wilderness Act of 1964, PFS has failed to adequately address the potential impacts of the Low Rail Spur and the associated fire buffer zone on this roadless, wild area. Specifically, PFS fails to analyze the impacts that the construction and operation of the proposed project will have on the North Cedar Mountains roadless area and its current status as an area which " generally appears to have been affected primarily by the forces of L

nature, with the imprint of[ human] work substantially unnoticeable." PFS fails to consider that l

the operation of the rail spur will significantly intrude upon the area's currently " outstanding l

opportunities for solitude." Finally, PFS does not adequately address the consequences of the 4

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construction and operation on the area's wildlife, wildlife habitat, plant life, and other ecosystem values which are essential to the ecological health of the area and favor it for wilderness designation. See, Amendment. See, PFS Amendment.

To establish the basis for this contention SUWA relies and intends to rely on: 1) the l

expert opinion of Dr. Jim Catlin and his affidavit attached to SUWA's petition and request; 2) maps, field notes, photographs and other information documenting SUWA's 1998 reinventory and in the possession of Dr. Catlin and SUWA; 3) Wilderness Act of 1964,16 U.S.C.A. @

1131-36, and the Federal Land Policy and Management Act of 1976 (FLPMA),43 U.S.C.A. @{

1701-84, National Environmental Policy Act of 1969 (NEPA), BLM regulations and other relevant statutes and regulations; and,4) the opinions of biological experts who consulted on the reinventory process including Dr. Leila M. Shultz of Harvard University.

l II.

CONTENTION B:

. Statement: ' The License Application Amendment fails to develop and analyze a j

. meaningful range of alternatives to the Low Corridor Rail Spur and the associated fire buffer zone that will preserve the wilderness character and the potential wilderness designation of a tract of roadless Bureau of Land Management (BLM) land - the North Cedar Mountains --

which it crosses.

Basis: ' SUWA incorporates as a basis for this Contention, the basis stated for Contention A. As was demonstrated in Contention A, despite the wilderness character of the North Cedar Mountains and its potential designation as wilderness pursuant to the Wilderness Act of 1964, PFS has failed to adequately develop and analyze a meaningful range of alternatives to the Low Rail Spur and the associated fire buffer zone on this roadless and the alignment of these proposed 5

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.h projects that will protect the wilderness character of the North Cedar Mountains and will preserve, for Congress, the opportunity to designate the area as wilderness pursuant to the Wilderness Act of 1964.

IIL Conclusion In sum, as a result of the inadequacies in the current application, the PFS's license application amendment should be rejected, SUWA should be allowed to intervene in this proceeding and these issues should be litigated in this proceeding.

Respectfully submitted this 18* day of November,1998 TXXDEC4idt Richard E. Condit Land and Water Fund of the Reckies 2260 Baseline Road, Suite 200

. Boulder, Colorado 80302

. (303) 444-1188 ext. 219 Boulder, Co 80302 C

Joro Walker Land and Water Fund of the Rockies 165 South Main Street, Suite 1 Salt Lake City, Utah 8411l' (801) 355-4545 Attorneys for Southern Utah Wilderness Alliance 6

f 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

.NOV 23 P4 :12 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDOR:

s Rut ADJUL m,y - ;gF

)

In the Matter of:

)

Docket No. 72-22-ISFSI

)

PRIVATE FUEL STORAGE, LLC

)

ASLBP No. 97-732-02-ISFSI (Independent Spent Fuel

)

Storage Instalhtion)

)

November 18,1998

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OGD's MOTION FOR LEAVE TO REPLY TO APPLICANT'S AND STAFF'S RESPONSES TO OGD's CONTENTIONS RELATING TO THE LOW RAIL TRANSPORTATION LICENSE AMENDMENT On or about August 28,1998, the Applicant amended its license application to account for a new transportation corridor and a change in the location of the Rowley Junction intermodal transfer facility. On November 2, -

1998, the OGD filed Contentions Q through Z. On November 3,1998, the Board issued an Order requiring that responses to OGD's contentions be filed by November 12,1998. The NRC Staff and the Applicant filed responses to OGD's Contentions on November 10 and 12,1998, resroctively.

Pursuant to Board's Memorandum and Orda o ~ Lruary 2,1998 (Memorializing Initial Prehearing Conference Directives), OGD requests leave i

to reply to the Staff's and Applicant's responses. According to the Board's L

Order, a reply from OGD would be due within ten days of the date the Staff and i

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Applicant filed their responses (i.e., on or before Monday, November 23, 1998). Order at 4, n. 3. OGD intends to limit its reply to each party to ten pages or less.

Counsel for the Staff and counsel for the Applicant do not oppose the i

Motion, DATED this 18th day of November,1998.

l Respectfully submitted, (s(;

1 Joro Walker, Esq.

Land and Water Fund 165 South Main Street, Suite 1 Salt Lake City, Utah 84111 -

801-355-4545 j

Richard E. Condit Land and Water Fund -

2260 Baseline Road, Suite 200 Boulder, Colorado 80302 303-444-1188 ext. 219 Counsel for OGD J.

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