Among the formal comments by the state: The plant would pose "an unacceptable terrorist target"; PFS has not demonstrated the financial and technical capability to build and operate the above-ground storage facility; slow-moving PFS trucks would pose a traffic hazard on the 20-foot-wide road; PFS proposes to ship in one year the number of nuclear fuel casks that had been shipped in 17 years.

"PFS's proposed intermodal facility is not a secure facility," state officials wrote. "The outer perimeter of the site will be fenced with a four-strand wire range fence (39 inches high) and the operations area will be enclosed with an eight-foot-high chain-link fence.

"In addition, the intermodal facility will not normally be staffed."

Operations will be restricted to daylight hours and will require a four-person crew, "who will also drive the heavy haul trucks to and from the (Goshute) Reservation," the document says.

"Therefore, spent nuclear fuel casks at the right of way will be left virtually unprotected while a crew transports a cask to the reservation site."

State officials noted that PFS plans to inspect the transportation casks at the reservation and reject any "if it detects a certain level of contamination. PFS then plans to ship the defective cask back to its owner."

The "significant problem" with that is that if a cask is malfunctioning, Union Pacific may not accept it for the return trip because the cask would violate requirements for the integrity of something being shipped.

"Therefore, the cask would remain at the BLM site. Furthermore, if the utility has completely decommissioned the reactor site, there would be no receiving entity to accept return shipment," says the state's comments.

The Healthy Environment Alliance of Utah announced Friday that more than 100 local and national organizations were asking BLM to deny the PFS request.

Jason Groenewold, director of the Salt Lake City-based group, added on Monday that HEAL also delivered to the BLM on Monday more than 700 comments on post cards.

In addition, the group helped send in 300 comments to the BLM through e-mail, Groenewold said.

Groenewold criticized last week's statement by Glenn A. Carpenter, manager of the BLM's Salt Lake field office, that comments should be substantive and not just opinion.

"The federal government should not minimize the public interest portion of their decision," Groenewold said. One of the agency's criteria is whether granting the permit would be in the public interest.

"That is where the sheer volume of public comments ... is critical," he added.

Telephone calls to PFS on Monday seeking a response to the statements were not immediately returned.

---

E-mail: bau@desnews.com