Mexico Building and Construction Trades Council. However, a heterogeneous coalition of environmentalists, ranchers, the oil and gas industry, and New Mexico’s Gov. Michelle Lujan Grisham all oppose the project. ISP’s proposal is a little less complicated seeing that an LLW storage facility already exists next to the proposed CISF. In both cases, a very long review period by the NRC is allowing the public to express any concerns they may have with the proposed CISFs. Whether the NRC or the companies take these concerns into consideration remains to be seen. Another concern that is often brought up regarding these industry efforts is the vastly condensed timeline they are proposing, especially when it comes to decommissioning. While the accelerated decommissioning model can return land to productive uses sooner, many stakeholders question “whether the rapid
timetables are safe and whether the companies have the expertise and the financial means to do the job” (Salsberg 2019). Finally, how do regulations for shipments and storage that were designed for government programs work for private industry programs? Of particular concern to states and Tribes is the status of Section 180(c). Part of the 1987 NWPAA, Section 180(c) directed the Secretary of Energy to provide technical assistance and funds for training in areas that would be affected by the transportation of SNF or HLW (see Section 180(c) AHWG for more information). It is clear that, because shipments conducted by private industry would not fall under the NWPA, states and Tribes would not be eligible to receive any assistance under Section 180(c). The question remains, therefore, who will pay for training and emergency preparedness? The answer increasingly appears to be the states, Tribes, and local governments.
Diagram 1
DOE Shipments Under the NWPA 1
Licensee Shipments
Security: DOT Overweight permits: States Route designation (highway): States
Route sharing: 2 weeks in advance; NRC Not required to share entire route(s) with states Aiming for 2023 shipments, pending CISF approval Licensee is fully responsible throughout shipment Standard Contract doesn’t apply NRC approval of routes
TEPP training: DOE Public outreach: DOE Funds for training:
Inspection requirements: Federal and States Preplan and coordinate with states: DOE, NRC Route identification (rail): DOT-PHMSA, NRC Route identification (highway): DOT-FMCSA, NRC Safety Compliance Oversight Plan (SCOP): DOT-FRA Escort requirements (security, safety): DOE, NRC, States Notification to Canada of shipment affecting the Great Lakes: Great Lakes Water Quality Agreement, Article 6
NWPA Section 180(c) State Regional Group coordination: DOE Curfews/key dates to avoid: States DOE has their own dedicated tracking system: TRANSCOM Additional carrier/driver requirements: DOE Route sharing:
CVSA Level VI Inspection (truck): DOT-FMCSA Required to have tracking system: DOE, NRC Continuous monitoring: DOE, NRC Advance notification: NRC 2 Package approval: NRC 3 State fees: States S-2043 railcar will be used: AAR
5 years in advance; DOE Standard Contract applies
Licensee provides properly loaded SNF packages to DOE at the site boundary NRC approval of routes not required
1 DOE has agreed to meet and/or exceed all NRC regulations, and is required to follow US DOT regulations 2 NWPA Section 180(b) 3 NWPA Section 180(a)
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