This concern over Section 180(c) was raised forcefully at the May 21, 2019, “Used Fuel Transportation: Table Top Exercise” sponsored by NEI and hosted by Xcel Energy’s Prairie Island Nuclear Generating Plant. The exercise simulated a private SNF shipment from a fictional nuclear power plant in the upper Midwest to a fictional CISF in the American Southwest. The objectives of this exercise were to: • Identify and discuss the key steps necessary to safely and efficiently transport used fuel from a nuclear power reactor site to a Consolidated Interim Storage Facility (CISF); • Identify relationships and demonstrate communications and decision-making among participants; and • Identify opportunities to streamline processes and improve regulatory efficiency (NEI 2019, p. 9). The exercise also served as an initial outreach effort by the nuclear energy industry to states and Tribes to share the industry’s perspective on the possibility of private SNF shipments, and to hear the questions and concerns that states and Tribes might have. In addition to voicing concerns about shortened timelines and confusion over regulatory processes, the issue of funding for training and preparation was top of mind for states and localities. Following up on the NEI exercise, the MRMTC held a similar “Spent Nuclear Fuel Transportation Workshop” on November 13, 2019, in Indianapolis, Indiana. This exercise simulated a bi-modal DOE SNF shipment from Big Rock Point, Michigan, to an unspecified location outside the Midwest. While the scenario was a DOE shipment, participants paused at steps along the way to see how a private
shipment would be different or similar. These similarities and differences between DOE SNF shipments completed under the NWPA and licensee SNF shipments were captured in part by the Venn diagram shown below (MRMTC 2019c). In addition to helping MRMTC members understand their responsibilities during a SNF shipment, the exercise was an important continuation of the dialogue begun with the nuclear industry. Moving forward, the MRMTC will be standing up a new work group in late 2020 based on the work done during the “SNF Transportation Workshop.” It will focus on preparing states for the possible shipment of SNF by private industry and working to ensure industry is aware of states’ transportation regulations and preferences. Moving forward, private industry can help assure the success of their radioactive materials ventures in two ways. First, they can continue to engage states and Tribes near the proposed CISF locations and along shipping routes in a manner that is transparent, phased, adaptive, as well as standards- and science- based. Second, given the inherent risks and the potential for high public interest in shipments, private activities need to proceed following the best practices previously recommended for shipments under the federal program. This means working with states and Tribes to identify a mutually acceptable means of funding their emergency preparedness, training, and transportation safety program needs so that taxpayers do not have to bear the costs of DOE’s inability to meet its NWPA obligations.
47
Made with FlippingBook Annual report