of following a seasonal shipping schedule by which sites in the northern part of the country would ship during warm-weather months and sites in southern locations would ship in the winter months. A seasonal shipping schedule could be consistent with the states’ desire to see OCRWM maximize the efficiency of its shipping queue by removing only fully loaded casks from each site that is scheduled to ship during the year, not just the amount specified in that site’s annual allocation. Seasonal shipping could also concentrate the impact on some states within a constrained time frame, thereby reducing the long-term burden placed on state government agencies charged with overseeing shipments. Possible drawbacks to seasonal shipping could include greater impacts on shipment duration due to road construction, difficulty identifying shipping dates that avoid key events and holidays in the states, and increased likelihood of encountering other types of inclement weather (e.g., tornadoes in the central U.S., ice storms in the South). As with all issues related to the shipping queue, making a seasonal schedule work would also depend on OCRWM’s ability to negotiate with purchasers over the terms of the Standard Contract. Whether the benefits of seasonal shipping would outweigh the costs can only be determined by a through feasibility assessment with input from all potentially affected parties.
which admittedly are the most common contingencies shipments might face. Actions by protestors or, in the case of train shipments, “rail fans”would be considered a security-related issue and would be addressed in security plans for shipments. The OCRWM report “Developing the Transportation System” addressed contingency planning only in the context of planning for early shipment. At the time of the report’s publication, OCRWM’s cask programs were on schedule to “provide a transportation capability for the CRWMS by the year 2000” (DOE 1994c, p. 3-22). The report noted, however, that OCRWM had “developed contingency plans in the event an interim storage site becomes available in the near future” (ibid.). The two options considered were using existing casks (with limited capacities) or using higher-capacity casks using the latest technology. OCRWM predicted that these newly designed casks “could be built and certified quickly if reliance was placed on design approach, materials, and technologies currently used in existing casks” (ibid.). In 1995, OCRWM published Revision 1 of its “Transportation Contingency Plan for Limited Capacity Shipment.” Like the 1994 “Developing the Transportation System,” this plan focused exclusively on the specific contingency of OCRWM being faced with ramping up the transportation system on a compressed schedule. In the “Transportation Contingency Plan,”OCRWM addressed institutional considerations that “must be addressed prior to Transportation System Element operation” (DOE 1995g, p. 14). The issues cited in the plan were a sampling of issues contained in the Transportation Institutional Plan or added at a later date, included routing, emergency preparedness, and full- scale testing of casks (ibid., pp. 14-15). The document is useful for getting a sense of what steps OCRWM would need to take in order to ship earlier than planned. Nevertheless, the states have repeatedly cautioned against the possibility of shipments occurring before all the institutional issues have been addressed to the mutual satisfaction of OCRWM and the affected states. OCRWM has demonstrated through activities like the development of the Section 180(c) policy and procedures that, when given proper direction and authority, the program can move swiftly to resolve even complicated issues. Other examples, however, such as route identification, call into question OCRWM’s ability to get things done on a tight schedule. During its discussions of the various issues pertaining to the provision of financial assistance to states and tribes, the Section 180(c) Topic Group considered contingency planning specifically with regard to rerouting. Appendix F of the group’s recommendations to OCRWM management addressed contingency re-routing during which shipments might need to be diverted to “a less prepared or unprepared route” (TEC 180c TG 2005, Appendix H, p. 1). The discussion paper noted that, while DOT does not require hazardous materials emergency response training as a “prerequisite” for hazardous materials shipments along a particular route, this fact “must be balanced against OCRWM’s legal mandate to provide assistance along shipping routes” (ibid.).
TRANSPORTATION OPERATIONAL CONTINGENCIES
Aside from a draft plan published in 1994, OCRWM did not produce much in the way of detail for what it would do in the event of operational contingencies such as weather-related delays or rerouting due to unforeseen events like natural disasters or damage to roadways or rails. OCRWM will need to produce detailed contingency plans — outlining specific steps the program and other entities will take in response to various scenarios — to build confidence in the planning for shipping spent fuel and high-level waste. Section 9 of the DOE Manual addresses transportation operational contingencies. As defined in the manual, operational contingencies are “taken in response to adverse weather, natural disasters, vehicle breakdown, travel and road/rail conditions, and unanticipated delays that could interrupt normal transportation of DOE shipments” (DOE 2008f, p. 31). The manual further explains that these contingencies can take place prior to departure or while a shipment is en route. The DOE Manual specifies actions DOE shippers, including OCRWM, should take, first, to avoid adverse travel conditions and, second, in the event unforeseen adverse conditions materialize while a shipment is en route (ibid., p. 31-32). While the manual provides clear guidance for truck shipments, it leaves decisions regarding rail shipments to the discretion of the carrier. The exception is that, “if an accident or incident results or develops, the DOE shipper will consult with appropriate States and Tribes” (ibid., p. 35). The emphasis in the manual is on adverse weather and road conditions,
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