consultation (not precisely specified) it will be contentious and may not work’” (ibid., p. 2). Williams stopped short of recommending specific actions to take to bring OCRWM and its stakeholders to a more clear, shared understanding of what consultation and cooperation mean. He concluded, however, that the “gap between the expressed consultation intent and actual consultation process is probably attributable to a combination of institutional and technical factors” (ibid., p. 7). These factors must be addressed in order to successfully resolve this issue. Being a “first concern,” it is imperative that any successor to OCRWM address this issue very early in the process of developing its transportation system. TRANSPORTATION PLANNING TIMELINE In the early years of the Yucca Mountain program, OCRWM consistently produced planning timelines in its transportation- related documents. These very broad timelines included target schedules for achieving milestones ranging from cask procurement to issue resolution. In recent years, however, OCRWM moved away from publishing detailed schedules for rolling out the transportation system, with the most recent transportation plan (January 2009) being published without any kind of schedule. The states in the Midwest and elsewhere would benefit from the publication of detailed planning timelines that cover all the steps in the transportation- planning process. Such information would help the states prepare for their role in helping to plan, oversee, and monitor OCRWM’s shipments. DOE’s TEC/WG developed a timeline with an acceptable level of detail in 2006 specifically for rail shipments. OCRWM neither adopted nor endorsed the timeline before transportation-related work ended in 2009. In the 1986 Transportation Business Plan , OCRWM published a schedule for the transportation program that showed the program’s goals for transportation systems acquisition, institutional programs, and“support to repository and MRS” (the last item relating to OCRWM’s compliance with the National Environmental Policy Act (NEPA)) (DOE 1986b, p. 6). The Transportation Business Plan also laid out timelines for Phases I and II of the Transportation Systems Acquisition activity. Later that same year, OCRWM published the Transportation Institutional Plan , which included a “Preliminary schedule for transportation policy decisions and activities” (DOE 1986c, p. A-4). As the Yucca Mountain program evolved, similar timelines appeared in later OCRWM documents such as the 1994 draft “Developing the Transportation System.”Dates shifted, activities were added and dropped as the need arose, but none of the later timelines that appeared in other OCRWM documents rivaled the relatively high quality of the timelines in the Transportation Institutional Plan or the Transportation Business Plan until the late 2000s. Recognizing that the affected states and tribes would benefit from schedules that showed all the planning steps in greater detail, in 2005 the TEC/WG Rail Topic Group organized a Planning Timeline
subgroup to develop a timeline that could be suitable for planning OCRWM shipments. As stated in the introduction to the document, the subgroup developed the timeline “to assist the TEC/WG members, DOE managers, and others understand the many steps — and the relationship between the steps — that can contribute to the successful movement of spent fuel and high-level radioactive waste to a national repository” (TEC Rail TG 2006a, p. 1). The level of detail in the timeline was intended to help all parties — states and tribes, carriers, OCRWM, and other federal agencies —“understand how and when they will be involved in shipment planning” (ibid.). In closing, the subgroup noted that the timeline provided an “excellent starting ground for identifying what interactions must take place, between what parties, and when” (ibid.). Two things distinguished the TEC/WG “Rail Planning Timeline” from earlier OCRWM attempts. First, the timeline was developed with input from many groups — states, tribes, federal agency staff, and DOE staff and contractors with shipment-planning experience. Not only did this mark a contrast to OCRWM’s timelines, which had been developed without any external input, but it also resulted in the timeline showing the steps all parties could be expected to take, not just OCRWM. Second, the OCRWM timelines covered the major milestones needed to reach the point of shipping, such as awarding contracts and completing operational testing (DOE 1994c, p. 3-9). In contrast, the “Rail Planning Timeline” addressed very specific steps in the planning process, starting as early as five years prior to the start of shipments. 13 As the planning horizon approached the start of shipments, the level of detail increased significantly. For example, the timeline showed steps to be taken during the shipment, less than 12 hours beforehand, and at least 24 hours before the start of shipments, among other time periods. The “Rail Planning Timeline” underwent extensive review by the TEC/WG as a whole and was published in final form in August 2006. This document represented the most detailed publicly available timeline for planning shipments associated with the OCRWM transportation program. Schedule” for the National Transportation Project. Like earlier OCRWM schedules, this one covered major operational and procurement milestones such as the awarding of contracts for the transportation, aging, and disposal (TAD) system and obtaining certificates of compliance for TADs and other new cask designs (DOE 2007a, p. 51). OCRWM retracted this pre-decisional draft of the transportation plan due to legal considerations. When the next version was released in January 2009, it did not contain any schedules for completing work on the transportation system. In 2007, OCRWM’s pre-decisional draft of the “National Transportation Plan” included a “Preliminary Milestone
13 The timeline included a group of steps whose timeframe could not be agreed to by all members of the subgroup. These activities were grouped together under the heading“’Prior to the First Shipment’ (indeterminate timeframe)” (TEC Rail TG 2006a, p. 11).
77
Made with FlippingBook Annual report