Stakeholder Involvement
Although well intentioned, DOE-NE’s rollout of stakeholder engagement activities as part of the new NFST Planning Project did not reflect careful planning. One of the objectives of the proposed new cooperative agreements with the SRGs was to“help ensure the implementation of a staged, adaptive, consent based transportation system for SNF and HLW” (ibid.). The BRC had applied the concept of “consent-based” to siting, not to transportation. DOE-NE tried to expand the concept to transportation, apparently overlooking or failing to understand that “consent-based transportation”would be impossible to achieve. As noted in CSG Midwest’s comments on the initial draft of the statement of objectives: A consent-based approach to transportation is not likely to work. OCRWM’s 2003 strategic plan said, ‘The OCRWM Office of National Transportation will work with interested parties in a collaborative process to build a transportation system that supports the OCRWMmission and effectively addresses the concerns of its stakeholders.’ I think this is the best one can do (Janairo 2012, p. 2). The “consent-based transportation” language remained in the statement of objectives for the cooperative agreements until their renewal in 2016. After establishing the cooperative agreements with the SRGs, the next major stakeholder engagement activity for the NFST Planning Project was to bring together the leaders and staff of the cooperative agreement groups to learn about the activities that were taking place within the project, consider how those would affect state governments, and suggest appropriate ways to involve states in those activities. Although transportation was the focus, the discussions also included activities such as the consent- based siting effort that DOE-NE eventually undertook in 2015. (See Consent-Based Siting for more information.) This group came to be known as the “Transportation Core Group,” and it held meetings once or twice each year from 2012 through 2019 with a few lapses along the way, reportedly due to program redirection and/or resource constraints. The Transportation Core Group represented an improvement over past coordination efforts by the former OCRWM. Unfortunately, Tribes were excluded from the first such meeting in October 2012 — an oversight that would take DOE-NE a few years to move past (see Tribal Engagement ). At this first meeting, the MRMTC presented its regional priorities for the work to be conducted under the new cooperative agreement. Referring to the BRC recommendation regarding a possible new entity for managing the waste management program, all items on the list were “activities for which the states (and other stakeholders) would have the same expectations regardless of who undertakes them— DOE or a new ‘fed corp’” (MRMTC 2012). All but one of the activities — route identification —were items that were not necessarily dependent upon DOE-NE identifying a storage or disposal site first.
Between 2010-2020, DOE made some progress on the stakeholder involvement front. Rising from the ashes of the Transportation External Coordination Working Group (TEC/WG), the new NTSF provided a much-needed forum for bringing states, Tribes, and DOE together to collaborate on projects related to policy and transportation planning. DOE-NE wisely used the NTSF to its advantage, standing up multiple AHWGs, or committees. In addition, DOE-NE created a Transportation Core Group to engage the leaders of the SRGs and the Tribal Radioactive Materials Transportation Committee (TRMTC, formerly known as the Tribal Caucus) in discussions regarding the activities of the Nuclear Fuels Storage and Transportation (NFST) Planning Project and, following a reorganization, the Office of Integrated Waste Management (IWM). 3 The Transportation Core Group structure also gave the states and Tribes a chance to share their perspectives, needs, and desires with DOE staff and management. The outcome overall, however, was a mixed bag largely due to the continuing on- again, off-again nature of the program’s outreach. Despite the best efforts of the frontline staff, establishing and maintaining strong stakeholder relationships will remain elusive to DOE- NE without sustained activities that are backed by a strong, unwavering commitment from management to regard the states and Tribes as partners instead of as adversaries or, equally bad, as a box that needs to be checked. TRANSPORTATION CORE GROUP In 2012, DOE-NE inherited the Yucca Mountain-related tasks formerly managed by OCRWM prior to its dissolution. Transportation and storage/disposal activities were organized into the NFST Planning Project and the Used Fuel Disposition R&D Campaign, respectively, both housed within the Office of Fuel Cycle Technologies. The purpose of the NFST Planning Project was to initiate planning for moving, at first, SNF from the nine shutdown sites to one or more consolidated storage facilities, as had been recommended by the BRC. Following up on the BRC recommendation regarding“prompt efforts to prepare for the eventual large-scale transport of spent nuclear fuel and high-level waste,”DOE-NE decided to re-engage the SRGs “… that have been involved in cooperative relationships with DOE for a number of years to assist DOE in planning for radioactive materials shipments” (DOE-NE 2012, p. 1).
3 In the years covered by this edition of the archive, the federal government’s work on what was originally termed the Civilian Radioactive Waste Management System was conducted by the NFST Planning Project and, later, the IWM. While the distinctions are relevant, the archive references “DOE-NE” in most cases instead of specifying which specific program/project was directly responsible.
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