“the Midwestern states recommend that no barge shipments take place on the Great Lakes” (MRMTC 2008a, p. 1). OCRWM reportedly conducted an analysis of barge as a shipping mode in 1985, but the program had not recently analyzed its shipping sites to determine which ones could viably ship by barge (DOE 1986c, A-90). From the inception of the OCRWM transportation program, states and other stakeholders have consistently expressed an interest in OCRWM’s selection of shipping mode from the various nuclear sites. Stakeholders requested that OCRWM identify the process by which it will evaluate and select shipping modes, including any criteria, such as cost and risk, that might be used in modal selection. OCRWM committed to doing so. Stakeholders further asked that OCRWM identify the intermodal requirements that would be needed to conduct individual shipments by two or more modes. OCRWM planned to procure shipping casks that could be transported by rail, truck, or barge, to offer flexibility in mode selection. Finally, stakeholders requested that OCRWM include cask design features that would facilitate retrieval of the casks in the event of a serious transportation accident. OCRWM committed to review such design features and finalize cask interface design guidelines (ibid., p. A-91). OCRWM had conducted several studies to evaluate the transportation infrastructure at commercial nuclear reactors in order to inform decisions about shipping mode and equipment needs. The Facility Interface Capability Assessment (FICA) was completed in 1992 and looked at utility capabilities for shipping spent fuel. The FICA was followed up in 2004 by a planning study to update the utilities’ the Facility Interface Data Sheets. The Near Site Transportation Infrastructure (NSTI) study, also completed in 1992, evaluated the road, rail, and barge access to each commercial nuclear plant (Viebrock and Mote 1992). OCRWM had planned to update the data from these studies as needed. The Yucca Mountain Final EIS, issued in 2002, analyzed a “mostly rail” scenario and a “mostly truck” scenario. In a 2004 Record of Decision, OCRWM selected “mostly rail” as the preferred method of transportation for shipments to a national repository (DOE 2004, p.18561). In a 2005 policy statement, OCRWM declared its intent to have rail shipments occur via dedicated train, meaning that trains shipping waste to the repository would not be shipping any other commodity. Benefits of using dedicated train service included lower costs, shorter transit times, less time in rail yards, and greater scheduling flexibility (DOE 2005, p.1). The Yucca Mountain Final EIS estimated that there would be approximately 9,600 rail and 1,100 truck shipments under the mostly rail scenario (DOE 2002, table J-1); however, the NAS pointed out that these estimates were based on the assumption that one rail shipment is equal to one waste package, when OCRWM has since stated that up to five railcars could travel together in one train (NAS 2006, p. 218). Thus, the actual number of rail shipments may be significantly lower. The Final EIS assumed that six sites that lacked
the capability to handle rail casks would ship by truck. A 1996 study commissioned by the state of Nevada looked at data from the FICA and NSTI and concluded that the most likely scenario would be for 17 commercial sites to ship via legal weight truck, accounting for at least 25 percent of the total shipping volume (Planning Information Corporation 1996, Section 11). In 2006, in Going the Distance , the NAS praised OCRWM’s decision to conduct shipments according to a “mostly rail” scenario, citing operational and safety advantages for rail over truck transport. The NAS urged OCRWM to fully implement the mostly rail decision through several activities, including helping ensure that utilities have the facilities necessary to utilize rail transport. Provisions of the standard contracts with utilities require that OCRWMwork with utilities to determine the mode of shipment. The NAS further encouraged OCRWM to utilize intermodal transport, including overweight truck and barge, in order to reduce the need for cross- country legal weight truck shipments of spent fuel. According to the NAS, updating the FICA and NSTI reports were two of the tasks that OCRWMmust complete in order to fully implement the mostly rail scenario (NAS 2006, p. 227). The NAS recognized that OCRWMwould need adequate resources to accomplish these and other tasks, and failure to do so could lead to a heavy reliance on trucks as a shipping mode. This would likely have the undesirable effect of reducing public confidence in OCRWM’s transportation program (ibid., p. 228). The pre-decisional draft of OCRWM’s “National Transportation Plan” listed “Modal Mix” among the “resolved transportation issues” 16 (DOE 2007a, p.7). However, the states will not consider this issue to be resolved until OCRWM identifies the shipping mode from each of its shipping sites. Rev. 0 of OCRWM’s “National Transportation Plan” states that, while the plan was to ship spent fuel and high-level waste by mostly rail, “such materials can be shipped safely regardless of mode or type of service due to the stringent regulatory standards in place and the robust nature of the transportation packages involved” (DOE 2009, p. 4). According to OCRWM, the benefits of relying predominantly on rail as a mode of transport were cost-related and operational, rather than related to safety, and determination of shipping mode would be made based on site-specific considerations. Rev. 0 of the “National Transportation Plan”described Site Campaign Plans being developed prior to the commencement of shipments, with the plans including information such as shipping mode, number of casks, number of shipments, route to be used, and the transportation provider. OCRWM anticipated developing these plans “in coordination with the shipping site, States, Tribes and commercial carriers at least two years prior to initiation of the campaign” (DOE 2007a, p. 17). However, decisions around mode and route will surely influence the training efforts undertaken by the states, which may begin more than two years prior to shipments.
16 The list of resolved transportation issues did not appear in Rev. 0 of the “National Transportation Plan” issued in January 2009.
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