March 1993

Ms. Elissa Turner
Mr. Jim Carlson
U.S. Department of Energy
Office of Civilian Radioactive Waste Management
RW-431
1000 Independence Ave, SW
Washington, D.C. 20585

Dear Ms. Turner/Mr. Carlson:

The Western Interstate Energy Board High-Level Radioactive Waste Committee is obligated to provide comments to the U.S. Department of Energy (DOE) on the Near-Site Transportation Infrastructure Report (NSTI) under the current scope of work pursuant to the five-year cooperative agreement with DOE, which expires on March 24, 1993.

Since 1987, the Committee has undertaken a strategic planning process for developing a transportation system for shipments of spent nuclear fuel and high-level radioactive waste under the Nuclear Waste Policy Act. Elements of the transportation system include: emergency preparedness, routing, cask development, modal analyses, infrastructure, etc. Infrastructure assessments and improvements are important aspects of a transportation system, but are not on the critical path. Nevertheless, the Committee commends DOE on the completion of the NSTI report and offers the following comments:

The report indicates that 36 of 76 sites currently have the capability to accept a 100 ton rail/barge cask. The number of rail capable sites increases to 53 if upgrades are implemented. Many sites will still have difficulty handling and receiving the large rail/barge cask, possibly precluding rail as a viable shipping option in some instances. As a result, DOE should assess the feasibility of intermodal shipments.

DOE's recent announcement to use multi-purpose containers for storage, transportation, and ultimate disposal of spent fuel -- containers which are expected to approach or exceed the dimensions of the 100 ton rail/barge cask used in the NSTI study, will have significant impacts on a transportation system, including facility access. To optimize a transportation system based on the MPC concept requires maximum use of rail from reactors to storage or disposal sites. Lack of rail access to reactor sites would either require use of smaller, lower capacity MPCs (with a resulting loss in system efficiency), costly upgrades, and/or intermodal shipments (e.g., heavy haul by truck to the nearest rail access). DOE should carefully consider the implications of facility access in programmatic decisions related to casks.

According to the report, 41 sites have barge access, including four of the ten sites in the West (Cooper, Diablo Canyon, Fort Calhoun, and Trojan). The number of facilities with barge access is higher than the Committee anticipated. If barge transport remains a viable option for NWPA shipments, DOE should begin a detailed assessment of relevant issues -- after soliciting state input.

Finally, the Committee formally requests that DOE provide copies of the NSTI and Facility Interface Capability Assessment (FICA) detailed site-specific reports for western reactors (attached page) for inclusion in the WIEB High-Level Radioactive Waste Transportation Library. This would allow western state representatives the opportunity to assess and verify the transportation impacts of various infrastructure limitations on reactors in their jurisdiction. Please send the WIEB office the reports as soon as they are available.

The Committee appreciates the regular updates DOE has provided on the status of the infrastructure reports and supports DOE's ongoing efforts to identify facility transportation constraints in its development of a transportation system for NWPA shipments. It is the Committee's understanding that DOE is now preparing Site Specific Transportation Planning Documents, which combine NSTI and FICA information along with utility mode selection as outlined in Delivery Commitment Schedule (DCS) filings. The Committee would appreciate hearing an update on those activities at its next meeting.

Sincerely,

Daniel Nix, Co-Chair
California Energy Commission

Joe Strolin, Co-Chair
Nevada Nuclear Waste Project Office

cc: Lisa Tillman, Contract Specialist

Reactor Sites in the West

Cooper
Diablo Canyon
Fort Calhoun
Fort St. Vrain
Humboldt Bay
Palo Verde
Rancho Seco
San Onofre
Trojan
Washington Nuclear

Please send copies of the NSTI and FICA detailed site specific reports to Jim Miernyk, Western Interstate Energy Board, 600 17th Street, Suite 1704 South, Denver, CO 80202. Call 303/573-8910 if there are any questions.