WAST Project Management Plan.” According to the TSOP, the purpose of the plan was to 1) provide “the concept of operations” for the OCRWM transportation program; 2) provide “a planning basis for lower level functions identified in the Transportation Subsystem design requirements documents;” and 3) describe “the Transportation Subsystem in terms of mission, organizational structure, and architecture” (DOE 1995i, p. 1). The TSOP described the transportation planning process as involving“long range planning” (occurring“one year or more before the commencement of a campaign year”) and“operations planning” (occurring within one year of a campaign’s start) (ibid., p. 13). As envisioned in 1995, there would be “two types of key campaign planning documents.”The “Campaign Plan”would be a “comprehensive document that provides a detailed description of all the activities required to move fuel from an acceptance site” to facilities for storage or disposal (ibid.). The “Annual Campaign Plan”would compile all the schedules for all campaign plans. Each shipping site would have its own“Site-Specific Servicing Plan,”which would be finalized“at least 18 months”before OCRWMwould deliver shipping casks to the site — 24 months in advance for shipments that would take place the first year of the program (ibid., p. 16). As with “Developing the Transportation System,” the MHLRWC found the TSOP to be “difficult to read” and lacking in “relevant specifications” (MHLRWC 1995, p. 1). As an example, the committee noted that “the reader…learns about DOE’s plans to have office equipment but not about the department’s protocols for safe parking and bad weather” (ibid.). In 2006, after a hiatus in transportation planning activities, OCRWM published a new“Transportation System Concept of Operations” (CONOPS) (Rev. 0). The document suffered from the same problem as earlier transportation program plans — namely, being densely packed, difficult to understand, and lacking in tangible details about operational procedures. The authors of the plan described it as “the core high-level OCRWM document
written to describe the Transportation System integrated design and present the vision, mission, and goals for Transportation System Operations” (DOE 2006d, p. 8). In Section 5, Technical Baseline for Transportation System Operations, OCRWM identified the “Transportation System Documents” and their relationship. The goal at the time was to have a Transportation Operations Plan feed into the Annual Shipping Plan and Site Campaign Plans. The link between the CONOPS and the Transportation Operations Plan was somewhat tenuous, with three documents or processes interspersed along the way (ibid., p. 17). The CONOPS described the “Transportation Operations Plan” as providing“well-defined operations, safety, security, and emergency response guidelines for the Transportation System” (ibid., p. 18). Instead of being the operational procedures plan, however, the Transportation Operations Plan would provide “the framework fromwhich detailed operational procedures [would] be developed” (ibid.). These procedures would address “several topical areas, including: campaign planning; shipment tracking, training; emergency response; safety; and security” (ibid.). Unlike the Transportation Institutional Plan and other earlier OCRWM documents, the CONOPS did not provide a schedule or target timeframe for developing the Transportation Operations Plan. Within a year of publishing the CONOPS, OCRWM produced an outline of a new“National Transportation Plan.”As with previous efforts at creating a comprehensive plan, this one fell short. In its comments on the outline, the Midwestern committee —now the Midwestern Radioactive Materials Transportation Committee (MRMTC) —observed that the “stated purpose of this plan is to ‘tell the story of how the [transportation] systemwill be developed and deployed” (MRMTC 2007, p. 1). The committee went on to note that “the system is sufficiently ‘developed’ for OCRWM to be telling the story of how waste will get from the power plants to the repository” (ibid.). In its comments, the committee asked when OCRWMwould“begin to develop an operations-focused transportation plan, covering activities such as tracking, inspections, and security” (ibid.). The region also noted that, at the 2007 TEC/WG meeting in Atlanta, OCRWM had taken the action item of producing a list of “all the transportation- related documents that [the program] had prepared and what their relationship is to one another” (ibid.). OCRWM did not follow through with this action item to produce a publicly available listing. In the summer of 2007, in time for the TEC/WG meeting, OCRWM produced the pre-decisional draft of the “National Transportation Plan.”The draft was a 54-page plan, with schedules and funding profiles, that included a list of transportation issues and their status (DOE 2007a, Table 2, Table 3, Section VI). The document was not the Transportation Operations Plan that the CONOPS had referred to, but instead outlined“the strategy and process for developing and implementing the transportation system,” including“how stakeholder collaboration [would] contribute to specific elements of the transportation system” (ibid., p. 1). The section on“Operational Planning”noted that, “[b]ecause of the early stage of system development, operational planning has been limited” (ibid., p. 17). Less than a month later, OCRWM retracted the document.
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