the requirements in 10 CFR Part 73” (DOE 2009, p. 19). The revised section also noted that OCRWM’s security planning would “include operational contingencies to address security concerns that may arise during transit” (ibid.). TERRORISM AND SABOTAGE Nevada has frequently raised concerns about the possibility of terrorism and sabotage in connection with repository shipments. The NRC imposes regulations to protect shipments through procedures designed to minimize the likelihood of an attack and limit the consequences should an attack occur. OCRWM has stated that it will adhere to all NRC security requirements, but OCRWM has not committed to taking any extra-regulatory measures to address the risk of terrorism and sabotage. The state of Nevada has repeatedly included terrorism and sabotage concerns in its list of recommendations to OCRWM with regard to the safety and security of nuclear waste shipments. While OCRWM has acknowledged the risks of potential terrorist attacks on shipments of high-level waste and spent fuel, analyses performed by contractors for Nevada have shown the potential consequences of such an attack to be many times greater than those reported by DOE in the Yucca Mountain Final EIS. The state urged OCRWM to fully address terrorism concerns in its transportation planning for repository shipments (Halstead et al. 2008, p. 5). The state has also called on the NRC to carry out rulemaking that will ensure that terrorism and sabotage concerns are addressed (Halstead et al. 2005, p. 8). In 1998, WGA passed a resolution calling on DOE to incorporate risk management for terrorism and sabotage into all
it had not been decided what the scope of activities would be or whether security clearances should be required. One activity that some of the Security Topic Group members had hoped to undertake was a review of a security-related recommendation that came out of the NAS’s 2006 report Going the Distance . In the report, the NAS recommended that “an independent examination of the security of spent fuel and high-level waste transportation should be carried out prior to the commencement of large-quantity shipments to a federal repository or to interim storage” (NAS 2006, p. 8). The NAS thought such an examination should “provide an integrated evaluation of the threat environment, the response of packages to credible malevolent acts, and operational security requirements for protecting spent fuel and high-level waste while in transport” (ibid.). While the study would necessarily involve safeguards information, the NAS encouraged the sharing of findings and recommendations with the public “to the fullest extent possible” (ibid., p. 9). This last recommendation was made “in the spirit of improving the quality of informed dialogue on this sensitive but important issue” (ibid., p. 216). OCRWM never reached the point of developing a security plan – at least not one that was available to the public. The transportation plans developed over the years do refer to shipment security. The 1994 “Developing the Transportation System,” for example, stated that “in-transit physical protection will comply with the OCRWM Safeguards and Security Plan which augment (sic) the requirements of 10 CFR 73.37” (DOE 1994c, p. 3-29). In the pre- decisional draft of the “National Transportation Plan,”OCRWM committed to conduct security planning “in accordance with NRC regulations in 10 CFR 73, or equivalent DOE requirements” (DOE 2007a, p. 31). The 2009 version of the plan modified this commitment to say simply that OCRWM would “meet or exceed
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