IV.  TRANSPORTATION

BACKGROUND

U.S. Department of Energy (DOE) nuclear waste transportation campaigns are large-scale, long-term and require integrated planning for mode and route choices. ECA members are impacted by these radioactive waste shipment campaigns because they are located along shipping routes or serve as points of origin or destination for radioactive wastes.

ISSUES

1. Issues¹ not addressed by DOT regulations or DOE procedures include:

1. The planning process required to identify the least-risk mode-route options.
2. The criteria for choice among mode-route options.
3. The participation of local governments in mode-route choices.
4. The equity between communities at sites from which radioactive waste is removed and those through which and to which it is transferred for disposal.
5. The level and types of coordination among DOE sites and headquarters agencies in the assessment process and in implementation.
6. The procedures by which DOE should assure that carriers adhere to mode-route choices determined through an integrated mode-route planning process.

2. Issues specific to highly funneled shipment campaigns include:

1. ECA communities are local governments. As such, they most directly and legitimately represent the concerns of residents and workers affected by DOE’s large-scale, long-term radioactive waste shipment campaigns.
2. Local governments provide facilities and services (e.g. police, fire, emergency response and medical services) necessary for the protection of health, safety and welfare at and in the vicinity of DOE sites, and along heavily impacted corridors of highly funneled DOE shipment campaigns.
3. Transport for disposal elsewhere is often needed for cost-effective cleanup and reuse of DOE sites. ECA communities have interests both in the cleanup and reuse of DOE sites and in the safety and equity (procedural, regional, and intergenerational) of the process.

RECOMMENDATIONS

Integrated planning should be conducted to identify the most appropriate mode-route options for large-scale, long-term DOE shipment campaigns. The evaluation of mode-route options should include representatives of local governments as well as state governments, carriers, and DOE operations agencies. Decisions among mode-route options should address both system-wide and equity considerations. DOE should consider the following recommendation before committing to use the mode-route decisions identified in an integrated planning process of high integrity.

1. Integrate planning for large-scale, long-term DOE shipment campaigns. Specific characteristics include the following:

1. Identify and assess all feasible mode-route combinations for the campaign. These options should not be limited to currently available transportation facilities.
2. Reflect the most reliable available estimates of the volumes requiring shipment, and the most reliable available transportation cost and risk factors.
3. Assess accident and radiological risks for each mode-route combination, and should specifically address local risk factors in origin and destination communities, and at key points along the transportation routes under consideration.
4. Identify the least-risk mode-route combination systemwide. It should present risk assessment findings on a state-by-state basis system-wide, and on a county-by-county basis in origin and destination states.
5. Assess the system-wide cost of each mode-route combination, applying life cycle cost²  assessment techniques. Mode-route decisions, however, should be based on safety and equity considerations primarily, and cost considerations secondarily.

3. Create an evaluation and decision process that is open and participatory. The process should include local governments representing shipment origins, destinations, and heavily impacted corridors. Specific characteristics include the following:

1. DOE headquarters should be directly responsible for the integrated planning, evaluation and decision processes conducted for large-scale, long-term shipment campaigns.
2. To oversee the planning and decision process for a large-scale, long-term shipment campaign, DOE should establish a Panel comprised of representatives of DOE operations offices, rail and highway carriers, and potentially affected states and local governments. The Panel should meet as a group at key stages of the integrated planning process.
3. The Panel should attempt to identify the best mode-route combination(s) for the large-scale, long-term DOE shipment campaign. Its criteria should be specific and should include a) the least-risk combination systemwide, b) equity considerations (particularly regarding the destination state and county, and heavily impacted corridors), c) the life-cycle cost-effectiveness of mode-route combinations, and d) mitigation measures. If more than one large-volume, long-term shipment campaign has the same disposal site destination, the decision criteria identified still apply, but with even greater weight to equity considerations.
4. The Panel should function as a decision-making body, and DOE should consider it as such. The Panel should seek consensus in decision-making and should employ innovative techniques to resolve differences among the parties and to identify legitimate and acceptable choices. Only in the event of impasse should DOE identify its own mode-route selection for a large-scale, long-term shipment campaign. Such a decision should be made at the DOE headquarters level, and should be reviewed with the Panel before it is finalized.
5. DOE should require use of the selected mode-route option(s) by its carriers, including monitoring of the campaign in process.
6. The Panel should be convened periodically to review and assess the implementation of the shipment campaign in process. If major problems are identified, the Panel should have authority to recommend revisiting the integrated planning process.
7. Congress should recognize that DOE shipping corridors must contend with unique issues relating to the transportation of nuclear materials and waste and hence should receive additional points in the analysis and scoring for future transportation funds.

3. Work with affected communities to address transportation safety issues by continuing its outreach activities and entering into Memorandum of Understandings (MOUs) with local governments at the origin and end points and along the transportation routes regarding transportation issues. These MOUs must outline the relationships and actions DOE plans to take while transporting radioactive and hazardous materials through an area, as well as what emergency response is required of the local government.

¹For clarity and specificity, the terms used are defined as follows:

•  A DOE shipment campaign is considered “large-scale and long-term” if projected shipments of a particular waste type exceed 1,000 over a 5-year period, or 200 over a 12-month period.
• “Waste types,” which may be transferred in large-scale, long-term DOE shipment campaigns include nonclassified shipments of types identified in the DOE’s draft transportation protocols: e.g. low-level wastes, mixed low-level wastes, Greater-Than-Class-C wastes, Special-Performance-Assessment-Required wastes, transuranic wastes (contact and remote handled), spent nuclear fuel and high-level wastes.
• A DOE shipment campaign is considered “highly-funneled” if more than half of the projected shipments of a particular waste type have a single destination, or if more than two-thirds have but two destinations.