US Ecology's (USE) Environmental Report (submitted July, 1990, in support of its license application to construct and operate a low-level radioactive waste disposal site), contains no discussion of sociocultural dimensions (i.e., community cohension, family stability, local attitudes and lifestyles, cultural values, or prevailing community problems). Further, there is no sociocultural analysis of said dimensions.The Boyd County Monitoring Committee, however, did commission a Sociocultural Assessment, which was completed in July, 1992. US Ecology conducted an "expedited cursory review" of that sociocultural assessment for the Central Interstate LLRW Commission, USE's final 3 page product being dated September 3, 1992.
USE discusses "Socioeconomics" in its Site Characterization Plan, dated June 9, 1989, at section 2.12, which provides in pertinent part (at page 107), as follows:
2.12.1 Regulatory Bases
This section is based on the following documents:2.12.2 Purpose of Task
- NUREG-0902
- NUREG-1300, Section 3.7
- NRC Regulatory Guide 4.18, Section 3.7
2.12.3 The purpose of these socioeconomic studies is to provide the information necessary to meet Federal, State, local, and Project requirements for the licensing and permitting of the disposal facility. As such, the work scope is designed to address a range of issues, including:
- Potential Project impacts on baseline socioeconomic characteristics, and accommodation of the Project labor force
- Population growth trends over the life of the facility and future develpoments (Section 2.12.2 and 2.1.3) in the area that may adversely affect the ability of the disposal facility to meet the performance abjectives of NDEC Title 194, Chapter 4, (NDEC, 1988b)
- Adequacy of the region to support project development (e.g., availability of labor and health and emergency services)
- Adequacy of transportation systems to safely transport waste (Section 2.1.4.7)
- Community acceptance [Emphasis supplied]
Sociocultural Analysis is a subpart of the Socioeconomics section of USE's Site Characterization Plan, providing in pertient part (at pages 111-112), as follows:
2.12.5 Sociocultural Analysis
The purpose of the sociocultural analysis is to establish the sociocultural baseline for the community and region. The scope of the work includes a survey and study of the following two major components of sociocultural analysis:2.12.5.1 Social Struction
- Social Structure
- Sociocultural Dimensions
Major communities within the region of the candidate site that may be affected by the Project, from a socioeconomic perspective, will be identified. For these communities, the social structure and significant institutions will be identified. Standard sociocultural methods will be used, including survey or secondary sources supplemented by interviews with applicable personnel from State and local government as well as private social agencies.2.12.5.2 Sociocultural Dimensions
Information on sociocultural dimensions will be collected for:
- Social structure and significant institutions of major communities within the region
- Community cohesion
- Family stability
- Local attitudes and lifestyles
- Cultural values
- Prevailing community issues (e.g., unemployment, crime, substance abuse, lack of family stability)
An attitudinal survey will be conducted using standard sociocultural methods. The survey will be supplemented by interviews with representatives from State, local, and private social agencies and governing bodies. Social issues in the study will be identified and described, as will public concerns regarding the Project. Existing and projected future social programs by State and local agencies will also be identified and described.
NUREG 0902, published April 1982, provides in pertinent part (at page 26), as follows:
A sociological analysis may also be appropriate. In such cases, attitudinal surveys should be performed during site charaterization. Sociocultural dimensions to be surveyed may include community cohesion, family stability, local attitudes and lifestyles, and prevailing community problems. As in the socioeconomic analysis, the project characteristics should be superimposed on the socicultural dimensions to identify project-related impacts such as changes in community composition, marital and family stability, cultural vaules, and other qualitiy of life indicators.NRC Regulatory Guide 4.18, Section 3.7, dated June 1983, provides in pertinent part (at page 4.18-15), as follows:
A sociocultural analysis may also be appropriate. In such cases, attitudinal surveys should be performed during site characterization. Sociocultural dimensions to be surveyed may include community cohesion, family stability, local attitudes and lifestyle, prevailing community problems, community composition, cultural values, and other quality-of-life indicators.
The regulatory gudiance documents state that, "A sociocultural analysis may be appropriate," and, that in such cases, "...attitudinal surveys should be performed...." In the instant case, a sociocultural analysis was clearly indicated, and all but required by the Commission's adoption of former Governor Orr's "10 Condtitions" and Nebraska law. The center-stone of Orr's "Conditions" was that a dispsoal site would not be located in a community without that community's consent.
If the intent of the Nebraska Unicameral that, "...every effort to locate the facility where community support is evident...." was not a sufficient indication that a sociocultural analysis was warrranted. [Which, apparently, it was, given that USE listed among the purposes of the Socioeconomic section 'community acceptance.'] The crystal clear indicator of the need for a sociocultural analysis was the manifest disruption of the communities within the three candidate site counties months prior to completion of USE's Site Characterization Plan.
USE's original Site Characterization Plan indicated that a socioculutral analysis would be a part of the site characterization. However, USE's Environmental Report contains no section on sociocultural analysis, indeed, there is no reference to sociocultural surveys or dimensions. This is but one of the blatant flaws of the Environmental Report.
Interestingly enough, USE did, in fact, authorize an attitudinal survey during the site characterization time-frame -- Spring 1989. That survey was conducted by SRI-Gallup. Among the questions asked of respondents in Boyd, Nemaha, and Nuckolls counties, were:
3. Do you personally strongly approve, somewhat approve,
somewhat disapprove, or strongly disapprove of having a
low-level radioactive waste facility in [fill in the county
name] county?10.Considering everything we've talked about, do you personally
strongly approve, somewhat approve, somewhat disapprove, or
strongly disapprove of having a low-level radioactive waste
facility in [fill in county name] county?Between questions 3 and 10, were several questions related to approval or dispproval based upon various qualifiers (e.g., money; the state controlling the design, building, and operation of the site; electric rates going up if no disposal site were built; better roads for your area if a disposal site is located there; jobs for young people).
USE does not include the results of that survey in its Environmental Report. Further, USE has never released the results of said survey. Clearly, from reviewing the survey instrument (questions asked), this attitudinal survey would have demonstrated, one way or another, whether "community support" was present. USE representatives have stated that the survey results are some how proprietary in nature, and therefore will not be released. USE representatives have also characterized the SRI-Gallup survey as nothing more than a tool to assist USE in developing its public participation program. In a letter to the Central Interstate LLRW Compact Commission (CIC), dated May 12, 1997, a representative of USE now claims, "A March 1989 marketing message test telephone survey... had little or no value as sociocultural research." The USE representative further claims, "I have requested to be allowed to examine the results from the 1989 marketing survey but my request was denied. I find it unlikely that anyone from US Ecology would have previously sought access to the survey or its results, or that they would have been granted access if they requested it." This is a real interesting approach for USE to take. USE paid for the survey [or more specifically the Major Generators by funding the CIC which pays USE paid for it], yet they claim they cannot get the results?!
The fact remains, that USE has in its possession [and if not in its possession, has the ability to obtain] the results of a survey that would provide the positivie proof of whether community support was evident during the site characterization time-frame, or (and perhaps more likely) community support did not exist.
