OCRWM’s lack of progress in identifying routes was not due to a failure to grasp the problem. Early on, for example, in the Transportation Institutional Plan , OCRWM identified highway and rail routing as separate issues requiring resolution (DOE 1986c, p. A-5). For highway routing, the program planned to“sponsor regional routing workshops to assist in the determination of appropriate parameters for a transportation analysis” that would inform the development of environmental impact statements for “candidate repository sites,”Yucca Mountain being one (ibid.). The topics planned for discussion included“specific route factors that could be considered, and the availability of route-specific data” (ibid.). OCRWM intended to develop“route-planning criteria…as an element of transportation operational procedures contained in the OCRWM’s comprehensive transportation plan,”with the criteria directing“the selection of routes that conform to all DOT requirements” (ibid.). For rail routing, OCRWM noted that there were “no Federal regulatory requirements for rail routing,” therefore the program planned to consult with other federal agencies regarding the need for such requirements. OCRWM also planned to“develop appropriate rail- routing criteria for NWPA shipments” (ibid., pp. A-5-6). In later years, various OCRWM reports document that the program intended to develop a “Route Selection Guidance Document” (DOE 1994a, p. 38) and/or a route selection policy (DOE 1994c, p. 5-2; DOE 1995e, p. 16). The OCRWM Transportation Report , for example, indicated that OCRWM would develop a “routing policy” that would “comply with DOT regulations” (DOE 1995e, p. 16). The report “Developing the Transportation System” also mentioned a “routing policy,” specifically to be developed with “[s]takeholder input and participation…through the TEC/WG” (DOE 1994c, p. 5-2). Using the input OCRWM would receive through the TEC/WG, from other DOE programs, and from other stakeholders, the program would develop a “DOE guidance document” on routing (ibid.). OCRWM’s routing policy never materialized, nor did the guidance document. In 1996, however, the TEC/WG organized a Routing Topic Group for the purpose of “address[ing] the routing issue in detail” (TEC Routing TG 1998, p. 1). Over a period of two years, the group produced a report entitled“Routing Issues Related to
U.S. Department of Energy Radioactive Materials Transportation: Discussion and Recommendations” (TEC Routing TG 1998). The report did an excellent job of describing the routing regulatory structure, as well as then-current DOE policies and plans. In addition, the report nicely summarized the concerns that DOE programs had with regard to“extraregulatory”measures related to route selection (Section IV). Balancing DOE’s concerns, stakeholder groups – states, tribes, local governments, and environmental groups – had an opportunity to provide their own perspectives on route selection. The paper documented an important aspect of route selection – namely, the fact that DOT regulations give the carrier the authority to select the routes for highway shipments (ibid., p. 6). Acknowledging that “in recent campaigns DOE has worked closer with the carrier and other federal, state, tribal, and local authorities in early identification of potential routes,” the paper noted that “[r]outing determinations are critically important to the Department, and as a matter of course DOE consults …closely with the carrier and affected states in making the final selection” (ibid., p. 7). The section on states’ perspectives (Section V) addressed this same topic, beginning with a statement that, because of their primary role in protecting public health and welfare, “states have an interest on behalf of their citizens to become involved in route selection for all types and modes of radioactive materials shipments” (ibid., p. 9). The states identified“three main goals” for “the ideal route selection process:” • Promote safety and public acceptance of the shipping routes by making the federal government, not a private company, accountable for route selection; • Allow resources (inspections, emergency response, etc.) to be focused by reducing the total number of potential routes; and • Give states and communities sufficient time to prepare for shipments by eliminating the uncertainty regarding which routes will be used (ibid., p. 10). The states recommended the WIPP program as “the base model which most states would like to see DOE follow in planning its large scale shipping campaigns that involve high-level radioactive materials” (ibid.). The process involved DOE’s Carlsbad Area Office
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