applicable Federal and State regulations, AAR (Association of American Railroad) rules, and industry standards” (DOE 2008f, p. 37). Not having ready access to AAR rules, industry standards, or even the applicable regulations in other states – and absent a detailed, written inspection log – it would be difficult for a state inspector or other official to know for certain what had transpired during previous inspections. In 2006, the Rail Topic Group of DOE’s TEC/WG established an Inspections Subgroup to begin discussions about developing a reciprocal rail inspection program – in effect, filling the role of the “study group”OCRWM had envisioned forming when the Transportation Institutional Plan was written in 1986. Led by two Midwestern state representatives and the region’s staff, the Inspections Subgroup held numerous conference calls with state inspectors, FRA personnel, rail industry representatives, and OCRWM staff and contractors. These discussions led to group members developing a proposed set of forms for documenting the items that FRA-certified state inspectors would check during their inspection of rail shipments of spent fuel and high-level waste. The forms would also identify any significant findings. All the information obtained during the inspection would be shared with states “downstream” so that, if they exercised their right to inspect a shipment, they would know what their colleagues in other states had done and had found. The goal of the subgroup’s effort was to establish a reciprocal inspection program that would facilitate the movement of rail shipments from their point of origin to their destination with as few en route stops as possible for inspections. In 2007, the subgroup wrapped up its work and presented the inspection forms to the full TEC/WG. Members of the group gave a presentation that year on the proposed program at the annual meeting of the Association of State Rail Safety Managers. It was the expectation of the TEC/WG Rail Topic Group members that OCRWMwould move the proposed program forward in a manner similar to what had transpired with the truck inspection program – namely, OCRWMwould“develop financial arrangements with a technical organization” to work with state inspectors on establishing a CVSA-like program for rail shipments (DOE 1986c, p. A-50). Unfortunately, OCRWM’s funding was severely cut due to the Obama Administration’s decision to terminate the Yucca Mountain project. All work on the inspection procedures being conducted by OCRWM and the TEC/WG Rail Topic Group ceased as a result of the funding cut. In the 2008 edition of the Midwest’s Planning Guide , the MRMTC expressed the states’ hope that the prototype inspection process developed through the TEC/WG would “eventually be established as a reciprocal program that can facilitate state inspections of rail shipments” (MRMTC 2008b, p. 19). In 2009, the Midwestern
committee revived the interregional discussions on the reciprocal rail inspection procedures. Through monthly conference calls, an interregional rail inspections work group – again led by the Midwest – assessed the status of the TEC/WG inspection forms and evaluated the options for going forward with the original forms, a significantly scaled back set of forms, or some version in between. By January 2010, the group members had agreed to move forward with the original forms, the rationale being that a strong program could only be produced by having a very strong starting point. The MRMTC wrote to the FRA on January 19, 2010, to transmit the proposed forms and to explain the Midwestern region’s desire to see the states “develop, test, and codify a national reciprocal rail inspection protocol before large quantities of highly radioactive waste begin to move by rail” (Rasmusson and Schmidt 2010, p. 1). Among the benefits of a reciprocal rail inspection protocol cited in the Midwest’s letter was increasing inspectors’ understanding of “what their counterparts are checking when they conduct inspections,”with the likely result of increasing the “level of confidence in…previously conducted inspections” (ibid.). The letter also identified three characteristics besides reciprocity that the Midwestern states felt were necessary for a rail inspection program to have the same effect as the CVSA procedures for truck: “a detailed listing of items checked and defects found; the ability to pass information along to inspectors in other states in a secure manner; and the signature of duly certified state inspectors who conduct the inspections” (ibid.). The letter closed by encouraging the FRA to“provide the resources necessary to further develop this protocol through the pilot testing phase and, ultimately, to endorse the final protocol for use by FRA-certified state rail safety inspectors” (ibid., p. 2). As of June 2010, the FRA has not responded to the Midwest’s letter. The rail inspections work group continues to have conference calls, with the states planning to pilot test the procedures. It is unclear how far this activity will be able to progress without a concerted effort by OCRWM (or another DOE program office) to identify and fund an appropriate “technical organization” to carry the work forward. The CVSA Level VI inspection program was developed over a period of 13 years. It took almost 20 years to reach the point of being required in DOT regulations. The timeframe for resolving rail inspection issues will likely be even longer, given the nature of rail shipments traveling on privately-owned rails. It is for this reason that the Midwestern states attempted to move forward with the task of developing reciprocal rail inspection procedures long before any large-scale shipping campaign would take place. OCRWM or its successor will need to work to complete this activity prior to commencing large-scale shipping campaigns to move spent fuel or high-level waste by rail.
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