operations (DOE 1995g). OCRWM described its approach to managing transportation risks in its “Transportation Risk Management Approach, Preliminary Draft,”which was issued May 31, 1995. This document describes the process that OCRWM planned to follow in order to manage the environmental, health, and safety risks associated with its transportation activities. According to this document, “The risk management process is a means of communicating, identifying, assessing, mitigating, reducing, and monitoring risks in an environment of open communication and active participation with stakeholders” (DOE 1995h, p. 1). The approach to risk management described by OCRWM included five major elements. “Risk communication and stakeholder interfaces” refers to the ways in which OCRWM incorporates input from stakeholders, including states, Tribes, communities through which shipments might travel, environmental groups, nuclear utilities, vendors, and other federal agencies. OCRWM identified cooperative agreements and the TEC/WG as the primary avenues through which OCRWM would communicate with stakeholders on transportation-related issues. The second element is “Risk identification,”which describes the dynamic process that involves gathering stakeholder input, examining historical data on risks associated with transportation activities, using modeling to extrapolate potential risks from various data sources, reviewing applicable statutory and regulatory requirements, exploring the programmatic risks such as uncertainties around policies, funding, and budgets, and obtaining expert judgments (ibid., p. 4). “Risk assessment”would be accomplished by acquiring appropriate data and developing risk assessment tools to analyze potential transportation risks. “Risk reduction”would be achieved by implementing measures to mitigate or reduce potential risks. These measures could be policies, procedures, recommendations, modifications to equipment, maintenance, or inspections. Finally, “risk monitoring” involves continually monitoring the effectiveness of risk reduction measures to ensure continuous improvements in risk management (ibid., p. 5). OCRWM concluded the “Transportation Risk Management Approach”document by acknowledging that public acceptance of transportation activities will be achieved by incorporating stakeholder input and utilizing appropriate and reliable methods for risk management. OCRWM stated its intent to develop a
“Transportation Risk Management Implementation Plan” to describe how the transportation risk management results would impact project decision-making. That document was never developed. OCRWM’s most recent discussion of its approach to risk management was in the pre-decisional draft of the “National Transportation Plan” circulated in July 2007. In the draft plan, OCRWM stated that its risk management program would focus on technical, cost, schedule, and programmatic risks, all of which could be influenced and mitigated (DOE 2007a, p. 19). OCRWM proposed the following approach to the risk management process: • Identify the risks that have the potential for adversely impacting the program; • Assess each risk to determine its relative impact on the program, with the goal of prioritizing risks for further handling; • Define options for handling or responding to the risk through avoidance, mitigation, management, or transfer to minimize the threats to achieving the program mission; and • Monitor the status of known risks and continuously evaluate the program to identify, analyze, and handle new risks (ibid.). The draft plan’s section on risk management did not include language on stakeholder involvement in identifying risks. OCRWM did not develop a “Transportation Risk Management Implementation Plan” to detail its methods for managing transportation risk. Also, OCRWM did not engage in a substantial way with stakeholders in the areas of risk identification and risk communication. These topics would presumably be addressed in the “Transportation Risk Management Implementation Plan,” if developed. Looking ahead, when OCRWM or its successor resumes work on a national transportation program, the “Transportation Risk Management Approach” from 1995 will need to be updated. The approach described in the document would seem to satisfy many of the later recommendations of the NWTRB and the NAS. However, in addition to stating its approach and issuing a risk management plan, OCRWM would need to actually establish a program for identifying, assessing, and managing transportation risks. To fully satisfy these recommendations, the risk management program would need to be established early with active involvement of stakeholders, be transparent, and utilize appropriate and reliable methods of analysis.
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