In February 2019, the FRA released an updated draft of its SCOP (FRA 2019). According to the FRA, while SNF has been transported by rail over the past several decades without any incidents resulting in injury or release of the material, these shipments remain the subject of public concern. It is expected that the vast majority of SNF and HLW currently being stored onsite at the nation’s commercial nuclear reactors will ultimately be shipped via rail to a repository or interim storage site. As such, the volume of rail shipments of SNF and HLW are expected to increase significantly in the coming decades. To ensure that these shipments can continue to be carried out safely even as their numbers increase significantly, the FRA developed its SCOP to address the safety of DOE’s rail shipments of SNF and HLW. The 2019 draft version of the SCOP describes the responsibilities of the various divisions within the FRA's Office of Railroad Safety to promote and regulate safety in SNF and HLW shipments (ibid.). As discussed in this archive’s original section on the SCOP, the first iteration of the FRA’s plan was developed in 1998 in response to concerns over rail shipments of foreign research reactor SNF and in anticipation of large-scale shipments of SNF and HLW within the U.S. SCOP development involved coordinated efforts among the FRA, DOE, the AAR, railroad labor organizations, and states. The original SCOP included tasks in the following areas: Operational Integrity (OI), Emergency Response (ER), Route Infrastructure Integrity (RII), Highway-Rail Grade Crossing Safety (GC), Security (S), and Miscellaneous (MIS). It further covered rail inspection policy regarding HLW. An update to the SCOP was seen as necessary to facilitate the development of a reciprocal rail inspection program and enable consideration of AAR Standard S-2043 (Maheras 2016). The FRA’s proposed revisions to the SCOP were reviewed and discussed by the R/R AHWG in 2019 and 2020. Much of the conversation focused on the differences between the 1998 and 2019 versions. According to FRA, one of the main motivations for revising the SCOP was to make it more accessible to FRA trained inspectors; for this reason, much of the introductory text that was present in the original SCOP was removed in the 2019 draft (R/R AHWG 2019b). The R/R AHWG discussed with the FRA whether the intended audience of the document was rail inspectors or the general public. Stakeholders suggested that, if the SCOP was primarily intended to be used by rail inspectors, a supplemental document providing more information on rail safety for SNF shipments would be needed to build awareness among other state and tribal personnel and to address public concerns over shipments (R/R AHWG 2019c). Comments provided by the MRMTC and Tony Leshinskie of the Northeast High-Level RadioactiveWaste Transportation Task Force were discussed on the September 2019 call of the R/R AHWG. Some stakeholders expressed concern that having the document focused primarily towards rail inspectors had resulted in the omission of information that some found useful in the initial document. CSG Midwest found it difficult to glean the responsibilities to be carried out given the current structure of the draft SCOP and provided specific examples of activities that had been clearly articulated in
the 1998 SCOP but were removed in the current version (MRMTC 2019b). The FRA explained that it intended for the revised SCOP to highlight the activities that were specific to SNF shipments and, as such, it removed the routine inspection information. The MRMTC and Mr. Leshinskie also noted that there appeared to be less detail in the proposed draft SCOP as compared with the 1998 version of the document (R/R AHWG 2019c). Another concern highlighted by the states was the apparent limited involvement of states contemplated in the document. As the MRMTC noted: The document is very light on details regarding how states can be involved in the various parts of the plan to ensure all activities occur —or seeing to it that the plan is carried out to ensure safety. We realize that the FRA staff are “boots on the ground” in many states, but if something were to happen, how can the state (or FRA) go back to elected officials and demonstrate that all of the procedures were followed and everything was good to go prior to the shipment occurring? (MRMTC 2019b, p. 2). The stated purpose of the SCOP was to address concerns regarding rail shipments of SNF, specifically, the “high degree of public awareness and concern regarding the safety and integrity of SNF and HLRW shipments by rail” (FRA, p. 6). Given this purpose, the MRMTC observed“that people will be asking questions and wanting to see that every precaution was being taken. In the final SCOP, it will be important to address how the various actions will be documented and how that information will be shared with the states” (MRMTC 2019b, p. 2). According to the FRA, it was working to maximize state involvement in rail shipment activities (R/R AHWG 2019c). The MRMTC inquired whether the S-2043 standard would be applied to all rail shipments of SNF and the FRA responded that it expected all shipments of SNF to be carried out using AAR S-2043 compliant railcars (MRMTC 2019c). Finally, there were concerns expressed by Tribal representatives about the language used regarding the Tribes and tribal lands; FRA committed to working with TRMTC to revise the language (R/R AHWG 2019c). The FRA had initially committed to revising its draft SCOP to incorporate comments received from stakeholders in advance of the 2020 NTSF Annual Meeting (R/R AHWG 2020a). The meeting was cancelled, however, due to the COVID-19 pandemic. In June 2020, FRA notified the R/R AHWG that the organization had undergone a reorganization and thus the draft SCOP had been resubmitted to the FRA legal department for review. The FRA expected to share a revised draft with the group within a month (R/R AHWG 2020b). Once the FRA issues its revised draft SCOP, states and other stakeholders will be afforded the opportunity to provide additional comments on the document and the potential need to develop an accompanying, public-facing document on the safety of rail shipments of SNF.
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