— should also be considered in contingency planning (ibid.). These recommendations were based on the experiences of other DOE shipping programs. Of the “commonly cited logistics issues” identified in the report, the only one mentioned by all six “lessons- learned” sources was “operational contingency plan” (ibid., Table 2). OCRWM’s 2009 “National Transportation Plan”was not the “comprehensive transportation plan” that the Section 180(c) Topic Group referred to in its recommendation regarding contingency re-routing. The plan did, however, shed some light on OCRWM’s plans to conduct contingency planning by stating that “contingency plans will be built into transportation campaign plans” (DOE 2009, p. 18). OCRWM identified some specific examples of transportation operational contingencies. For example, in the event of bad weather and other natural phenomena, which are “local and transitory in nature,”OCRWMwould“instruct commercial highway carriers to follow directions issued by local law enforcement and other authorities regarding route conditions and travel restrictions” (ibid., pp. 18-19). If such contingencies occurred during the course of a rail shipment, OCRWM expected the shipments to proceed“under railroad operating procedures” (ibid., p. 19). Other contingencies cited in the plan were mechanical and changes in scheduling (ibid.). Appendix H of the Supplemental Environmental Impact Statement provided additional detail about OCRWM’s plans for dealing with contingencies. This section, however, like the DOE Manual, was unnecessarily restrictive in considering primarily weather and road conditions as operational contingencies (DOE 2008c). The Midwestern Radioactive Materials Transportation Committee addressed operational contingencies in the region’s Planning Guide for Shipments of Radioactive Materials through the Midwestern States , which contains sections on bad weather and road conditions, as well as safe parking (MRMTC 2008b, p. 21-23). Because the states have first- hand experience with the conditions that are likely to arise in their states — and the appropriate response actions to take —OCRWM should work closely with the states when it develops its operational contingency plan for shipments of spent fuel and high-level waste. TRANSPORTATION PLANNING The states in the Midwest and elsewhere are strong advocates for OCRWM conducting transportation planning in a consultative fashion on a regional level, with appropriate interactions among the regions and other stakeholder groups. OCRWM first established cooperative agreements with regional groups of states in the mid-1980s. By 1995, OCRWM had reached out to all four regions of the country, engaging states through agreements with WIEB, the Southern States Energy Board, CSG Midwest, and the CSG Eastern Regional Conference. Over the years, the states consistently maintained that a regional approach to transportation planning was the best option for managing a national transportation program. In its “Report Card” on OCRWM’s transportation program, WIEB advocated for a regional approach in the broader context of modeling the transportation program — or at least the institutional part of it — on the transportation system that DOE developed for shipments of transuranic waste
The paper described the proposal in the 1998 version of the 180(c) policy and procedures: specifically, the policy stated that “eligible states and tribes may receive an additional amount of financial assistance if asked to complete activities in shorter amounts of time” (ibid., p. 2). This situation would pertain to three different scenarios: a route is selected too close to the start of shipments to allow for Section 180(c) implementation; a route is closed while a shipment is en route; or no training (or insufficient training) has occurred along the route “as a result of fraudulent actions or non-cooperation by a state or tribe along the route” (ibid.). As noted in the paper, a weakness of this approach was that two of the scenarios would be the result of “poor planning, not unforeseen events” (ibid.). The topic group recommended that “instances of poor planning should not be considered in contingency planning” (ibid.). Instead, the members of the group defined a contingency, “for the purposes of the 180(c) program, [as] an occurrence such as an emergency route closure that turns into a long-term route closure that affects planned or on-going shipments” (ibid., p. 3). In the event of contingency re-routing, the topic group recommended that OCRWM should “make funds available, if necessary, and work with state, local and tribal governments as necessary to reach a mutually acceptable solution” (ibid.). The group further recommended that contingency re-routing “be considered as part of a comprehensive transportation plan, rather than limiting the discussion to Section 180(c) concerns” (ibid.). OCRWM’s 2007 “Benchmarking” report recommended that a contingency plan should“identify who is involved and who the responsible parties are,” including“how the States and Tribes will be involved, contingencies for weather and adverse road/track conditions, and provisions that will be made in the event of an unplanned detour” (DOE 2007d, p. 15). The report further stated that any incidents that could interfere with shipments — such as “accidents, vehicle breakdown, and threats against the shipment”
75
Made with FlippingBook Annual report