Transportation Institutional Issues: The Post Yucca Years

Transportation Planning

control system for the OCRWM and contractor management” (ibid., p. A-107). OCRWM described the manual “as a road map to provide guidelines for uniformity in overall transportation operations, similar to other manuals that exist in the transportation industry today” (ibid.). Indeed, the Transportation Institutional Plan specifically mentioned that OCRWMwould use the experience of other DOE programs as well as “the electric utilities and the transportation industry” in developing the transportation system for the repository program (ibid., p. A-105). Given the early stage of planning in 1986, the Transportation Institutional Plan contained a “preliminary outline of the contents of the [Operations Procedures] manual” that is impressive in its detail, including among the many steps Operational Scheduling, Shipment Checkout, as well as Shipment in Transit (ibid., pp. A-107-108). In the 1990s, OCRWM produced many plans that addressed operational procedures. In June 1994, the program published “Developing the Transportation System,”which purportedly “supersede[d] the Transportation Institutional Plan … and the Transportation Business Plan ” (DOE 1994c, p. i). The report was “intended to provide an overview of the OCRWM national transportation program,” focusing “on the development of an operational system” (ibid., p. 1-1). In reviewing the document, the Midwestern High-Level Radioactive Waste Committee (MHLRWC) noted that, while the draft plan did “an adequate job of describing the transportation component of the Civilian Radioactive Waste Management System..., much of the information contained in the document is presented in a manner that makes it unintelligible to the general reader” (MHLRWC 1994, p. 1). The committee observed that the critical section — Chapter 3, on “Development of the OCRWM Transportation System”—was “particularly hard to follow, even for stakeholders who are already familiar with the program” (ibid.). Key among the committee’s recommendations was the need to make the document a “complete yet reader-friendly source of information on the transportation system”with the committee suggesting that OCRWM enlist the help of the writers who had prepared the program’s many factsheets (ibid.). OCRWM did not finalize “Developing the Transportation System,” choosing instead to produce a new OCRWM Transportation Report . The preface to the report explained that OCRWM had decided “not to combine the Transportation Business Plan , Transportation Institutional Plan , and operations plan into one document” (DOE 1995e, p. i). The rationale for the change in approach was that OCRWM had produced other documents that “reflected” the program’s plans for the transportation system (ibid.). The new Transportation Report would “report on the status of OCRWM’s transportation system,” giving “special emphasis to ‘institutional issues’” (ibid.). The intention was to update the report annually; the 1995 edition, however, was the only one OCRWM prepared. One of the documents the Transportation Report cited was the “Transportation System Operations Plan” (TSOP), which OCRWM’s 1994 Program Plan included as a milestone for FY95 (DOE 1994a, p. 38). OCRWM’s management and operating contractor released Revision 0 of the “Transportation Subsystem Operations Plan” in February 1995, designating the document as “Volume 15 of the

OPERATIONAL PROCEDURES When OCRWM director Ward Sproat testified before Congress in 2006, he identified as one of his four strategic objectives “to develop and begin implementation of a comprehensive national spent fuel transportation plan that accommodates state, local and tribal concerns and input to the greatest extent practicable” (Sproat 2006, p. 6). Three years later, the program met this objective, on paper, by publishing for comment Rev. 0 of OCRWM’s “National Transportation Plan.” The document, however, fell far short of the expectations Mr. Sproat’s pledge had created. Instead of describing how a typical shipment would take place, the document focused more on the development of the transportation system itself. The Midwest has advocated for OCRWM to develop a detailed transportation operations plan. The Midwestern Radioactive Materials Transportation Committee’s “key OCRWM issues” for FY09 included the need for OCRWM to develop “a transportation operations plan in the very near term” (MRMTC 2008a, p. 1). The committee observed that “[a] well-crafted plan will be adaptable to changes in shipping sites, destinations, and modes…and would demonstrate OCRWM’s ability to conduct shipments in a safe and timely manner to both Yucca Mountain and temporary storage facilities” (ibid.). The Midwest and other stakeholders have consistently urged OCRWM to use as models for its transportation plan the plans of successful shipping campaigns such as WIPP and the Foreign Research Reactor (FRR) program. While OCRWM’s benchmarking study did identify aspects of these programs that were important “lessons learned” for the repository transportation system, OCRWM’s latest transportation plans do not reflect attempts to use these programs’ planning documents as a guide. OCRWM identified the issue of transportation operational procedures in response to stakeholder feedback. In its discussion paper on this topic in 1986, OCRWM laid out a 10- year schedule that included holding a workshop “to discuss the outline of operational factors,” producing a “preliminary outline of operational factors,” and defining “general operational procedures” for a “comprehensive transportation plan” (DOE 1986c, p. A-105). The Transportation Institutional Plan also identified “procedural considerations” that would affect the transportation plan, including the “operations-management structure” for the transportation program and the program’s “strategy for rate negotiation” (ibid.). OCRWM’s plan in 1986 was to develop a “Transportation Operations Procedures Manual” that would“serve as a management guide and

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