the NAS Committee on Transportation of RadioactiveWaste gave its strong endorsement to“the use of full-scale testing to determine how packages will perform under both regulatory and credible extraregulatory conditions” (NAS 2006, p. 14). The NAS recommended that “full-scale package testing should continue to be used as part of integrated analytical, computer simulation, scale-model, and testing programs to validate package performance” (ibid.). The committee stated that testing“to destruction” should not be required (ibid., p. 15). In 1999, the NRC got involved in the issue when it initiated a “Package Performance Study.”While emphasizing that shipments of spent fuel in the U.S. were safe using“current regulations and programs,” the commission undertook the Package Performance Study with the goal of testing“the robustness and capability of spent fuel packages to withstand accident conditions significantly beyond the regulatory limits” (NRC 2003b, p. 13). As described in the draft testing protocol issued in 2003, the study would involve “tests of full-scale rail and full-scale truck casks including a high-speed impact with an unyielding surface followed by an extreme fire test” (NRC 2003a, p. iii). The NRC had contracted with Sandia National Laboratories for the impact and fire tests, as well as for some of the analytical work. The commission staff felt the proposed tests would help the NRC meet the objective of “enhancing public confidence in the inherent safety of spent nuclear fuel cask design, validating the capability of the cask models and analysis codes to accurately capture cask and fuel response to extreme mechanical and thermal environments, and providing data to refine dose risk estimates” (ibid.). The states in the Midwest, as well as other stakeholders, were involved in discussions regarding the scope and objectives of the Package Performance Study. In a 2002 letter to the NRC staff in anticipation of regional workshops, the CSG Midwest staff noted that the committee had“repeatedly urged [OCRWM] to conduct full- scale testing” and had hoped“to be involved in developing the test protocols if OCRWMwere ever to commit to full-scale testing (Sattler 2002, p. 1). The letter further observed that the NRC was, “in essence, doing what the Midwestern committee had asked OCRWM to do,” and went on to endorse the idea of an NRC-managed test: “Having the regulator conduct the test is…a better approach than having OCRWM do so” (ibid.). Stakeholders had an opportunity to participate in three public workshops in 2003 with the NRC staff to review the draft protocol and further refine the NRC’s plans. The Midwestern states were well represented at the Chicago-area workshop. Starting in the spring of 2004, the NRC staff began corresponding with the commissioners regarding the recommendations for testing. Over the course of the next year, the plan changed several times. In May 2004, the commission approved the staff’s request to conduct a full-scale test of a rail cask and directed the staff to seek funding from OCRWM to help pay for the test. The commission further instructed the staff to continue its interactions with OCRWM to determine whether and, if so, when it would be possible to perform testing on a certified truck cask (Vietti-Cook 2004a, p. 2). In July 2004, the NRC staff sought the commission’s approval of the testing plan, as well as approval to proceed with a “demonstration test involving the collision of a
locomotive and a rail cask attached to a railcar,”with the inclusion of a “fully engulfing fire” (Reyes 2004, p. 4). The paper described the test as representative of conditions that, in a “real-world accident,”would have a “small”probability of occurring (ibid.). In December 2004, the commission modified the plan for testing. Specifically, the commission authorized the staff to conduct a test that consisted of “a simulated rail crossing with a train traveling at an appropriate speed colliding at a ninety degree angle with a transportation cask on its rail carrier car in a normal transportation configuration” (Vietti-Cook 2004b, p. 1). Although the staff had recommended a test involving a fully engulfing fire, the commission said“no separate fire testing or immersion testing will be conducted on the cask” (Vietti-Cook 2004b, p. 1). The commission described the modified test as representing“a viable transportation accident” and felt that the test would be “one means of increasing public confidence in the viability of existing spent fuel transportation casks” (ibid.). In 2005, the commission modified the plan yet again, instructing the staff to include a fully engulfing fire in the test (Vietti- Cook 2005, p. 1). The commission directed the staff to approach OCRWMmanagement about providing financial support for the demonstration test, with a request to Congress being an option if OCRWM did not provide the necessary resources (ibid.). As of June 2010, the NRC has not followed through with its plans to conduct full-scale testing. This issue, therefore, remains open. INTERMODAL SHIPMENTS Intermodal shipments became an issue because OCRWM decided to ship spent fuel and high-level waste by mostly rail, but currently 25 commercial reactor sites do not have rail capabilities. OCRWM has not yet identified how intermodal transport will be arranged. States are interested in where shipments will transfer from one mode to another and what kind of state oversight will be necessary for intermodal transfers. OCRWM and stakeholders began to identify the issues related to intermodal shipments to take place through the TEC/WG Rail Topic Group’s Intermodal Subgroup in 2007. The subgroup was unable to complete its work due to the termination of the TEC/WG in 2009. OCRWM determined in 2004 that shipments from the 76 commercial reactor sites and five DOE sites to a federal repository would occur by “mostly rail” (DOE 2004, p. 18558). According to OCRWM, as of 2008, 25 commercial reactor sites did not have direct rail access (Thrower et al. 2008, p. 5). An additional six commercial sites did not have the capability to load rail casks: Crystal River, Saint Lucie, Pilgrim, Monticello, Ginna, and Indian Point. The Yucca Mountain Final EIS assumes that these sites would likely ship their inventory of spent fuel via legal weight truck. In 2005, OCRWM announced plans to use TAD canisters for transporting spent fuel and disposing of it at the Yucca Mountain repository. According to OCRWM, TADs in overpacks would be too large and heavy to be shipped by legal weight or even overweight truck. Options for shipping these canisters include rail, barge, or heavy haul truck.
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