operating reactors” (ibid., p. 238). The NAS expressed the belief that a pilot program involving shipments from shut-down reactors would help DOE “gain experience and build public confidence by demonstrating an ability to transport spent fuel to Yucca Mountain in a safe, secure, and operationally effective manner” (ibid., p. 246). In Rev. 0 of the “National Transportation Plan,”OCRWM indicated that it would conduct “pilot projects to assess the adequacy of policies, procedures, and processes that are unique to OCRWM’s transportation system” (DOE 2009, p. 19). Indeed, this suggestion was one of the recommendations in OCRWM’s own benchmarking report, published in 2007: “Extensively pilot test and refine plans, equipment and operations” (DOE 2007c, p. iii). That report compiled the lessons learned from various DOE shipping programs, including theWIPP program. The report described theWIPP“demonstration program,” involving prototype casks, that “focused on stakeholder interactions, emergency response preparedness, and public education” (ibid., p. 24). TheWIPP contributors to the report noted that “the demonstration program could have been even more effective”had it included testing of the equipment “under routine and continuous operating conditions;”“notification procedures for an in-transit emergency, and the joint information center response;” and“addressing the possible need to reverse shipments due to unexpected rejection of waste at WIPP” (ibid.). TheWIPP program also recommended that OCRWM conduct “extensive operational readiness reviews with utility sites,” since the shipping sites’ ability to meet their waste characterization and packaging goals proved to be an early challenge for theWIPP program (ibid.). According to Rev. 0 of OCRWM’s plan, the purpose of the OCRWM pilot projects would be to“support system development before larger scale investments are made and before commencement of full-scale operations” (DOE 2009, p. 19). This description is consistent with the type of pilot identified in OCRWM’s benchmarking report. The “National Transportation Plan”did not provide much in the way of detail, therefore it is unclear whether OCRWM envisioned the same kind of pilot shipping program— specifically one involving spent fuel from shut-down reactors — that the NAS had recommended in 2006. The earlier, pre-decisional draft of the transportation plan sheds some light on OCRWM’s plans for the pilot projects. OCRWM cited as one example “training in cask handling for the logistics operator, for repository personnel and for shipping sites using non-radioactive and non-contaminated cask systems” (DOE 2007a, p. 31). The plan also mentioned the long-planned pilot of the Section 180(c) program assistance. With regard to actual shipments, however, the only plans OCRWM had were to ship“empty casks using contracted carriers and selected routes,”which would involve “carriers, state, tribal and local officials in OCRWM shipment operations before loaded casks are shipped” (ibid.). It appears, therefore, that OCRWM had different plans than the NAS did for pilot testing the transportation system. OCRWM’s 2008 Report to Congress on the Demonstration of the Interim Storage of Spent Nuclear Fuel gave OCRWM an opportunity to address the NAS’s recommendation directly. Congress had requested the report in the House Appropriations Committee report on the Consolidated Appropriations Act of 2008.
In 2009, just days before the inauguration of President Barack Obama, OCRWM published for comment a new version of the “National Transportation Plan,” labeled“Revision 0.”Half the length of the pre-decisional draft, the new plan lacked the detail provided in the earlier plan, with no schedules or cost projections. The plan also lacked information on the status of various institutional issues, covering only Section 180(c) implementation and route identification (DOE 2009, pp. 23-25). In comments on the plan, the Midwest explained that “the brevity of our comments reflects the level of detail OCRWM included in Rev. 0 of the transportation plan” (Leuer and Rasmusson 2009b, p. 1). The region committed to providing“a much more extensive set of comments in the future when OCRWM produces a truly comprehensive national transportation plan” (ibid.). The Midwest’s joint letter with the West and the Northeast similarly observed that there were some “significant deficiencies in the plan,” noting that “[a] great deal of work remains to be done before the plan will be the ‘comprehensive national transportation plan’ committed to by former OCRWM director Edward Sproat” (Niles et al. 2009, p. 1). In closing, the regions expressed their disappointment that OCRWM had“made the decision to solicit input on the “National Transportation Plan” formally through the Federal Register but not to respond to stakeholder comments with a comment-response document or with further stakeholder discussion” (ibid., p. 2). The regions urged OCRWM to reconsider this decision, as well as to“post the comments received on the programwebsite so that a record of the input received [would] be available to stakeholders and to future federal staff tasked with completing the transportation plan” (ibid.). OCRWM did not follow through on this suggestion. PILOT PROGRAM Some groups have recommended that OCRWM initiate shipments on a small scale with a pilot program so as to work out the bugs in the system before launching the full-scale transportation program. OCRWM acknowledged the benefits of a pilot program in its 2007 report Radioactive Waste Logistics Benchmarking and announced its plans to conduct “pilot projects” in versions of its transportation plan. OCRWM provided little in the way of detail, however, regarding the scope and schedule for its pilot testing. In its 2006 study Going the Distance , the NAS alluded to the advantages of a small-scale pilot program in its finding on the acceptance order for spent fuel shipments under the NWPA. Specifically, the NAS found that there were “clear transportation operations and safety advantages to be gained from shipping older spent fuel first and for initiating the transportation program with relatively short, logistically simple movements to gain experience and build operator and public confidence” (NAS 2006, p. 19). From this finding, the NAS recommended that “DOE… initiate transport through a pilot program involving relatively short, logistically simple movements of older fuel from closed reactors….DOE should use the lessons learned from this pilot activity to initiate its full-scale transportation program from
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