flexibility over the commercial spent fuel acceptance order (ibid., p. 260). Unpredictable and inadequate funding has made it impossible to invest in the necessary transportation infrastructure according to schedule. The inability to dictate a shipping queue will make it very difficult for the transportation program to operate effectively (see the section on Shipment Scheduling ). In addition, the entire OCRWM transportation program has been built around the assumption that OCRWM will be shipping waste to a repository at Yucca Mountain; the federal government may instead move commercial spent fuel to one or more interim storage sites to fulfill its obligations under the NWPA, and the current program may not have the flexibility to adapt to a changing mission. In order to successfully carry out a complex, national shipping campaign, the transportation program must examine the interconnections among the components. The NAS “saw clear evidence that the current organizational structure for the transportation program is impeding such an integrated approach because, as noted previously, the program does not have the autonomy and funding necessary to execute its mission” (ibid., p. 272). Specifically, the NAS noted that under the current structure, the transportation program competes within OCRWM for funding (ibid., p. 262). The entire OCRWM program has been underfunded, which has led to decisions being made based on funding availability rather than on a technical basis. The NAS recommended changing the management structure of DOE’s transportation program to improve the chances of success. The committee offered several potential alternatives for changing the management structure, but the primary objectives in making the changes were to provide the programwith greater budgetary flexibility, more planning authority, and flexibility to support a changing mission. The NAS described three alternative management structures that could be set up to meet these objectives.
The first alternative management structure would involve creating a Nuclear Waste Transportation Administration, quasi- independent DOE program office that could be given the authority to tap the Nuclear Waste Fund without prior Congressional authorization. This structure would have the advantage of giving the transportation program more autonomy to pursue its mission by removing the budget, schedule, and personnel constraints imposed by OCRWM management. It would provide the predictability and continuity in funding necessary to make the long-term commitments to develop the national transportation infrastructure. Creating this quasi-independent DOE office would be allowed under the provisions of the NWPA, but Congressional action would be needed to make the Nuclear Waste Fund available to the Nuclear Waste Transportation Administration (ibid., p. 267). The second option for changing the management structure of the transportation programwould be the creation of a quasi- government corporation that would operate like a private sector organization, but be partially owned by the government. This organizational structure is utilized by British Nuclear Fuels Limited and the French company AREVA, which are both private companies owned partially by their governments (ibid., p. 268). Under this structure, the corporation would be given authority to take title to commercial spent fuel for the purpose of transportation. DOE would take title to the shipped materials at the destination, which could be a repository or interim storage facility. This arrangement would have the advantage of bringing private-sector efficiencies to the transportation program, and would eliminate the current situation in which the government is regulating itself. One potential disadvantage of this structure is that the corporation could be less accountable to the public, but the NAS suggested that this could be addressed by including public participation requirements in the corporation’s charter. Changes to the NWPA would be required in order to utilize this quasi-corporate model (ibid.). The third alternative examined by the NAS is to create a fully private corporation operated by the nuclear industry. This alternative would have most of the same advantages and disadvantages as the quasi-government corporation option. It might be the best way to address the issue of the spent fuel shipping queue because it would create the collective economic incentive for spent fuel owners, who are also corporate owners, to maximize the efficiency of the transportation program. This model would also require changes to the NWPA. General changes to OCRWM’s management structure had earlier been recommended by the NWTRB. In a 1993 Special Report to Congress and the Secretary of Energy , the Board found that “The large number of organizations involved in the U.S. program and the diffuse nature of its organizational structure create substantial challenges for program managers. As a result, management problems seem to be adversely affecting some critical technical aspects of the program” (NWTRB 1993, p. v). The Board noted that, in most other countries, either spent fuel producers bear the responsibility for waste management, including storage, transportation, and disposal, or a government corporation
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