For the 25 sites that have the ability to load rail casks, but do not have direct rail access, OCRWMwas considering the use of intermodal shipments utilizing heavy haul truck or barge to move materials from facilities to the nearest rail head. From there, casks could be loaded onto rail cars and shipped the rest of the way to the repository. OCRWM had not identified how it would arrange intermodal transport. For example, OCRWM never proposed locations at which shipments would transfer from one mode to another, nor did it work with stakeholders to identify the kind of oversight and procedures that would be necessary for intermodal transfers. In 2007, the TEC/WG formed the Rail Topic Group’s Intermodal Subgroup to begin exploring and addressing the issues around intermodal shipments of spent fuel. The subgroup was charged with “identifying operational factors that complicate or increase the risk of intermodal transport from specific sites and developing recommendations for requirements and procedures to ensure safe and secure transfers of SNF/HLW at intermodal transfer stations” (TEC Intermodal Subgroup 2008b, p. 1). The subgroup convened conference calls between the summer of 2007 and fall 2008. There was one in-person meeting of the Intermodal Subgroup at the February 2008 TEC/WG meeting in San Antonio, TX. The Intermodal Subgroup identified a series of questions and concerns that states have with regard to intermodal shipments. Several subgroup members attended a panel discussion on “Stakeholder Perspectives on the Intermodal Transportation of Used Fuel” at the Nuclear Energy Institute’s Dry Storage Information Forum held in May 2008. Specific topics about which states expressed concern included routing, permitting, regulatory and jurisdictional issues, protection of infrastructure, transfer logistics, and public relations (ibid.). Questions from the subgroup were posed to a panel of speakers who had experience with intermodal shipments and panel members’ answers were recorded in a question-and-answer document (TEC Intermodal Subgroup 2008a). Speakers from commercial shipping companies were able to describe some of the equipment and processes for conducting intermodal shipments and transferring heavy loads from one mode to another. State speakers on the panel described their experiences working with shippers and state and federal agencies in planning intermodal shipments of large reactor components. In general, speakers expressed confidence that intermodal shipments could be carried out smoothly, and the panel participants had not run into many logistical issues in executing shipments. Shippers and state officials did stress that planning shipments several years in advance was the best way to avoid complications, recommending that involved parties be brought together to meet and discuss potential issues, such as man-made or naturally-caused interruptions to a shipment (ibid.). The Intermodal Subgroup had planned to contact commercial shippers to further discuss the logistics of intermodal shipments
and identify the factors that potentially complicate such shipments. The goal of these discussions would be to recommend procedures to minimize complications with OCRWM’s intermodal shipments of spent fuel. Because OCRWM cancelled TEC/WG activities, the Intermodal Subgroup did not complete a final work product. Two members of the subgroup — Bob Halstead and Fred Dilger, working for Nevada’s Agency for Nuclear Projects — prepared a paper entitled “Shipping Site Intermodal Transportation” (Dilger and Halstead 2007). The authors shared their paper with the subgroup. The paper used data on shipping mode from the Yucca Mountain Final EIS to explore the possible implications for intermodal shipments. According to the paper, shipping sites that do not have direct rail access “pose a major transportation challenge” (Dilger and Halstead 2007, p. 1). Several aspects of intermodal transport were particularly troubling to the authors. Dilger and Halstead pointed out almost one-third (32.3 percent) of the total 63,000 (Metric tons of uranium) MTU of commercial spent fuel that would be shipped to the proposed repository over the first 24 years of operation would originate from the 24 shipping sites without direct rail access 14 (ibid., p.2). As previously mentioned, sites that lack direct rail access would likely ship rail casks via heavy haul truck or barge to a conveniently located railhead. Seventeen sites could potentially ship by barge, resulting in as many as 1,575 barge shipments over 24 years. Dilger and Halstead made some assumptions about the ports that would be the destination for barge shipments and concluded that if all the sites that were capable of shipping by barge were to do so, “at least 18 states could be affected by coastal, inland waterway, and Great Lakes barge shipments of spent fuel” (ibid.). The authors further speculated that, if OCRWM shipped the oldest fuel first, as many stakeholders have proposed, almost one-half (47.6 percent) of the spent fuel shipped in the first five years of repository operation would be intermodal shipments from sites without rail access. In addition, the six sites expected to ship by legal weight truck would also begin shipping early on in the program, meaning that many states would need to prepare for rail, truck, and intermodal shipments during the first several years of repository operations (ibid.). The paper made the argument that OCRWM should begin detailed planning for intermodal shipments immediately to address issues such as transfer locations and procedures (ibid., p.1). Through the Intermodal Subgroup, OCRWM offered many detailed comments on the Dilger/Halstead paper (DOE 2008a). OCRWM objected to some of the claims made in the paper. For instance, OCRWM noted that the Dilger/Halstead paper was based on information from the 2002 Yucca Mountain Final EIS and should be updated data to reflect the data in the 2007 Supplemental EIS. In addition to noting that more recent data were available in the Supplemental EIS, OCRWM challenged Dilger and Halstead’s claims
14 In their paper, Dilger and Halstead identified 23 sites without rail access. OCRWM has identified 25 sites without rail access. There are two reasons for the discrepancy. First, Dilger and Halstead considered Salem and Hope Creek to be one shipping site. Second, OCRWM’s 2002 Yucca Mountain Final EIS assumed that the Humboldt Bay site was served by rail, but the 2007 Supplemental EIS reported that the site is not. Dilger and Halstead used the 2002 data and thus their paper did not anticipate intermodal shipments from Humboldt Bay.
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