shipments (DOE 2007a, p. 14). The document listed the issue of overweight trucks among the “resolved transportation issues” (ibid., p. 8); however, the “resolved” issue pertained to whether it would be legal for OCRWM to use overweight truck shipments given the divisibility of the load. According to the plan, “The use of overweight trucks was determined to be acceptable for the OCRWM Program because the payload is not divisible and the packaging alone makes shipments overweight” (ibid.). By 2008, however, it became clear that overweight truck shipments might, indeed, be part of the repository transportation program. The Supplemental EIS, published in 2008, corrected an error in the earlier Final EIS (2002), which had estimated the weight of trucks carrying high-capacity truck casks to be 80,000 lbs. Instead, in the later report, OCRWM acknowledged that trucks carrying casks “would be more likely to have gross vehicle weights in the range of 36,000 to 52,000 kilograms (80,000 to 115,000 pounds)” and would, therefore, be considered overweight (DOE 2008c, p. 6-5). OCRWM asserted that “the impacts from the use of overweight trucks for shipments of spent nuclear fuel would be similar to the impacts from the use of legal- weight trucks” (ibid.). While the environmental impacts of overweight trucks might, indeed, be similar, OCRWM anticipated additional work associated with their use: “Most states require transportation companies to obtain permits when their vehicles exceed weight limits to control time and place of movement. Local jurisdictions also often require overweight permits” (ibid., p. H-7). As noted in the Supplemental EIS, the purpose of such permitting was to protect highways and infrastructure such as bridges, to consider local traffic volume and patterns, and to protect the public that would be on the road. Because decisions on permitting were dependent upon each jurisdiction’s unique characteristics, state and local governments did not have uniform criteria for permitting shipments (ibid.). The realization that truck casks would need to be shipped on overweight trucks resulted in the 2009 version of the “National Transportation Plan” including “overweight/legal weight truck” as a transport mode “for commercial SNF sites that do not have the capability to handle rail casks” (DOE 2009, p. 5). OCRWM indicated that it would make modal decisions on a site-specific basis. RAIL ACCESS As of 2008, 47 of the 72 sites on which commercial nuclear power plants were located had rail access (Thrower et al. 2008, p. 5). Some of these sites were served by major railroads, while others were served by small “shortline railroads.” No systematic assessment of the rail infrastructure had been completed for these sites, therefore the Federal Railroad Administration (FRA) initiated a study to evaluate the quality of track near or adjacent to nuclear reactors served by shortline railroads. OCRWM initially provided funding for the study, however the cancellation of the Yucca Mountain program left the study incomplete. OCRWM determined in 2004 that shipments from the 72 commercial reactor sites and five DOE sites to a federal repository would occur by “mostly rail.” Since Yucca Mountain was not
According to OCRWM’s proposed policy for providing Section 180(c) funding to states and tribes, OCRWM anticipates making planning and assessment grants available four years prior to shipments (see the section on Section 180(c) Implementation ). Training grants would be available for three years leading up to shipments (DOE 2008e, p. 64936). States and tribes would likely want decisions regarding the shipping mode and the routes to be made early enough to inform their requests for Section 180(c) funding. OVERWEIGHT TRUCKS Among the drivers behind OCRWM’s development of high- capacity legal-weight trucks were the desire to reduce the impacts on roads of overweight trucks and to avoid the need for special permits issued by states. OCRWM’s decision to ship mostly by rail gave some added reassurance that overweight truck shipments would not be necessary. OCRWM’s Supplemental Environmental Impact Statement, however, indicated that overweight trucks might be back on the table. The issue of overweight trucks was first identified in the 1986 Transportation Institutional Plan as one of the nine original discussion papers. OCRWM’s interest in overweight trucks stemmed from the desire to reduce the number of highway shipments that would be required to move spent fuel to NWPA facilities. In that early paper, OCRWM indicated it was studying the federal and state weight limits for highways, examining the costs and safety of overweight truck shipments, and looking into the link between vehicle “highway damage and vehicle weight” (DOE 1986c, p. A-7). The program pledged to work cooperatively with states on “evaluations of the feasibility of using overweight trucks for NWPA shipments and the potential for developing nationally uniform and stable State permit procedures” (ibid.). OCRWM expected to make a final decision on the use of overweight trucks in 1990, noting that the ability to reach national consensus on state permitting procedures would be a deciding factor (ibid., p. A-8). In 1994, when OCRWM published its initial draft transportation plan, the program fully intended to use a combination of newly developed high-capacity legal-weight truck casks and rail casks, including MPCs. The report mentioned overweight trucks only in the context of “Contingency Plans for Early Shipment.”OCRWM listed two overweight truck designs – the TN-8 and TN-9 – as among the casks potentially available for use on a contingency basis, stating that, “if needed, some of these casks could be obtained to provide a very limited shipping capability” (DOE 1994c, pp. 3-22-23). By 1995, when OCRWM published its “Transportation Contingency Plan for Limited Capacity Shipment,” the decision had apparently been made not to utilize overweight trucks: “Over-weight trucks will not be used due to the additional permitting requirements for over-weight shipments. Consequently, the IF-300, TN-8, and TN-9 were not considered for contingency use” (DOE 1995g, p. 7). The 2007 pre-decisional draft of OCRWM’s “National Transportation Plan” likewise did not mention overweight trucks as a possible shipping option, solely referring to rail, legal weight truck, heavy- haul truck (for shipping rail casks to nearby railheads), and barge
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