In November 2015, Lisa Janairo (CSG Midwest) and Kelly Horn, Illinois Office of Nuclear Safety, distributed a draft issue paper entitled“Selection of Routes for Shipments of Spent Nuclear Fuel from Shutdown Reactors” to the R/R AHWG. The Midwest’s Paper focused largely on the historical routing work accomplished under DOE’s OCRWM) and asserted that much of that work remains relevant because the states’ positions on route selection are largely the same today. The states’ goals, which were documented in two papers by the TEC/WG Routing and Rail Topic Groups, could be summarized as follows: 1) make the federal government accountable for route selection; 2) focus resources by reducing the total number of shipping routes; 3) eliminate uncertainty around which routes will be used; 4) consult with affected states and Tribes, as well as rail carriers; and 5) promote safety in route selection (Janairo and Horn 2017). Both DOE-NE’s draft paper and the Midwest’s issue paper discussed potential principles that could be used to select rail routes and suggested processes for ultimately deciding on the set of routes that could be utilized for shipping SNF and HLW to a consolidated interim storage facility or repository. The early stages of route selection proposed in the two papers involve working with stakeholders through the R/R AHWG to develop routing criteria and using the START to generate routes that meet those criteria. The draft DOE paper proposed that, once initial routes were generated in START, the routes would be provided to rail carriers for independent analysis before sending a revised set of routes back to states and Tribes for review and analysis (Runyon 2015). The Midwest instead proposed to have the criteria refined and potentially reapplied to generate a new set of proposed routes (ibid.). A period of negotiation between DOE and stakeholders prior to final route selection was proposed in both methodologies. At the November 2015 meeting of the R/R AHWG in Des Moines, there was some discussion of merging historical background from the Midwest’s paper with the routing methodology proposed in DOE-NE’s draft paper. It was noted that much of the rail routing work that occurred under OCRWM took place prior to the development of PHMSA’s hazmat rail routing rule, which was promulgated in 2008. However, the AHWG pointed out that the 27 factors listed in the PHMSA rule were open to interpretation regarding how they would be applied. AHWG members decided to table analysis of the two routing process papers and instead conduct a series of webinars with regulators and members of the rail industry intended to inform working group members on rail operations and requirements. Once working group members had a better understanding of rail industry operations, the AHWG planned to hold a workshop with states, Tribes, DOE, the FRA, and representatives from the Class 1 railroads to discuss routing so that stakeholders could increase their understanding of how railroads designated routes and the railroads could understand the considerations that were most important to states and Tribes. The Ad HocWorking Group carried out its plan to hold three webinars on aspects of rail transport safety between February and May 2016. The webinars covered the five FRA inspection disciplines at the time: Motive Power and Equipment, Signal & Train Control,
Track, Operating Practices, and Hazardous Materials. In addition, the webinars addressed the FRA’s State Rail Safety Participation Program; regulatory requirements for routing rail shipments (the PHMSA hazmat rail routing rule); the FRA’s approach to rail carrier audits; and the industry perspective on rail transport safety, route selection, inspections, and transport of radioactive materials and other hazmat. Collectively, more than 200 participants attended these webinars; there was overlap with some participants attending more than one session. The AHWG next turned its attention to planning the routing workshop. AHWG members noted that, in previous transportation planning efforts, the focus in route selection had been to avoid population exposure. While the AHWG agreed that population dose exposure would not be significant during routine transportation, there was still concern around exposure that could occur as a result of a transportation incident. The group decided that a correlation analysis of the 27 factors included in the PHMSA rule would determine whether a shorter list of primary and secondary factors could be developed (Bickford et al. 2019). State and tribal volunteers selected reactor sites within their jurisdictions and used START to develop sample routes to Class 1 railroads using the factors that they felt were of greatest importance. Representatives from the Class 1 railroads were asked to identify routes for the same origin/destination pairs to allow for a comparison between routes generated in START and those developed through the rail industry’s proprietary Rail Corridor Risk Management System (RCRMS) model. The RCRMS software is not available to DOE or transportation stakeholders because of security sensitivities. The proprietary nature of this routing software contributes to public uncertainty about route selection (ibid.).
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