At the January 1995 meeting of the Transportation External Coordination Working Group (TEC), the Department of Energy released two draft discussion papers: Highway Route Selection for DOE Unclassified HRCQ Shipments ("Highway Routing Discussion Paper"); and Rail Route Selection for DOE Unclassified HRCQ Shipments ("Rail Routing Discussion Paper"). The Committee fears that use of the simplistic routing methodologies proposed in the papers will result in nomination of unspportable routes that will be rejected under public scrutiny. This will only further delay implementation of a safe and practical nuclear waste transportation system. Neither paper adequately addresses the central questions of the public residing along proposed routes. Citizens along shipping routes need to know: 1) if the route chosen was the safest route, and 2) whether all reasonable efforts have been made to make the chosen route acceptably safe. The papers do not propose route selection methodologies which answer these questions.
The Highway Routing Discussion Paper fails to address important issues which will have a significant impact on establishing the safest transportation. For example, only time, distance, total population, and urban populations are considered in the highway route selection process. Important safety factors which are not considered include: minimizing truck accident rates, minimizing emergency response time, avoiding difficult to evacuate populations, minimizing transit through inclement weather, avoiding "high hazards", and imposing time-of-day travel restrictions.
The Rail Routing Discussion Paper is an even further departure from a safety-based routing methodology. For example, the paper does not provide guidance on how DOE will determine when to use general freight, a dedicated train, or special train service, and how that choice may affect routes selected. No guidance is provided on the role safety should play in selecting a type of train service. The proposed rail routing methodology itself is little more than an effort to simulate current private railroad practices; it does not evaluate the safety of such practices compared with other route selection methodologies. In some circumstances, elements of the proposed methodology may worsen safety, such as giving preference to routes where the originating railroads keeps shipments on its system as long as possible. Further, the Rail Routing Discussion Paper offers no justification in terms of safety (e.g., minimizing rail accident rates) for the weights given different track classifications in the model.
By emphasizing administratively simple methodologies, both papers fall far short of providing comprehensive methodologies for evaluating options for NWPA shipping routes. Neither paper satisfies the primary objective of identifying the safest routes possible.
The Committee urges DOE to move expeditiously to improve the proposed methodologies and to ensure that the rigor of the methodologies is commensurate with the scale and duration of shipments contemplated under the Nuclear Waste Policy Act. The proposed schedule for finalizing the routing methodologies is too optimistic, given the inappropriate foundation laid in the initial draft of the Discussion Papers. However, we urge DOE to invest the effort to develop effective routing methodologies for NWPA shipments as soon as possible. Until DOE establishes route selection methodologies which adequately address safety issues, further steps in the development of a working transportation plan, such as the provision of funding under section 180(c) of the NWPA, cannot be taken.
As DOE proceeds to rework the proposed methodologies, we encourage the Department to consider existing state routing studies. We also urge that DOE establish the External Modal Working Groups it proposed earlier. Such working groups can the forum for identify workable routing methodologies which address safety.
Background
The Committee's approach to selecting shipping routes for shipments under the Nuclear Waste Policy Act (NWPA) is based on three goals:
1. Promote public acceptance of the selected route by eliminating the carrier's role in selecting routes and substituting defensible route-specific analyses and appropriate mitigation measures;
2. Allow resources (inspections, emergency response, etc.) to be focused by limiting shipments to as few routes as possible; and
3. Give states and communities sufficient time to prepare for shipments by eliminating the uncertainty regarding which routes will be used well before shipments begin.
In 1988, the Committee prepared a paper, Route Selection for Shipments to a High-Level Radioactive Waste Repository, which posed four central issues: (1) How many routes? (2) When should a route(s) be selected? (3) Who should select the route(s); and (4) What process should be used to select routes? While the focus of the Committee's paper was highway routing, the issues also apply to rail routing.
Based on DOE's issuance of the Highway Routing Discussion Paper, it appears that the Department has decided that it should play a central role in selecting highway shipment routes and that this critical decision should not be left to the carrier. If that is so, we concur with DOE's decision. The Rail Routing Discussion Paper does not make clear that DOE will, in practice, play a central role in selecting rail routes. The proposed model for rail routing appears to be merely a confirmation of existing industry practices.
The Highway Routing Discussion Paper appears to endorse a "National-to-Local" routing process, rather than a Local-to-National process. For discussion of optional approaches to routing see the Committee's paper Route Selection for Shipments to a High-Level Radioactive Waste Repository, 1988. If that is so, we again concur with DOE's decision. The Highway Routing Discussion Paper proposes one possible National-to-Local routing process. Our detailed comments focus on the proposed "National-to-Local" highway routing process. The role of DOE in identifying a national-to-local rail routing is unclear from the Rail Routing Discussion Paper.
As to how many routes should be selected, it appears that as a result of the proposed analyses DOE will identify one route from each origin to the destination. If that is so, we concur with DOE's decision. The Committee has evaluated the issues of single versus multiple routes from a shipping origin to a destination and concluded that the preferred general policy is to designate a single shipping route rather than multiple routes.
On the issue of when routes should be selected, the Discussion Papers are silent. The Committee urges DOE to address this issue. The Committee has evaluated the question of when NWPA routes need to be selected. See the enclosed copy of the Committee's 1993 Transportation Implications for Various NWPA Program Options which provides insights on the question of when routes should be selected.
Following are the HLW Committee's detailed comments on the Highway Routing and Rail Routing Discussion Papers.
Analysis of Discussion Paper
The Discussion Paper correctly concludes that HM-164 may not result in a single preferred route, particularly when shipments cover long distances where multiple combinations of Interstate highways are possible from an origin to a destination. The Discussion Paper also correctly summarizes DOT routing rules governing pick-up and delivery and preferred routes.
Unfortunately, the DOT rules are based solely on minimizing miles traveled (in the case of pick-up and delivery) and time in transit (in the case of preferred routes). Other risk factors are not addressed or are left to state designations of preferred routes. In 1992, DOT issued guidelines to assist states in exercising their authority to identify preferred highway shipping routes in the publication entitled, Guidelines for Selecting Preferred Highway Routes for Highway Route Controlled Quantity Shipments of Radioactive Materials. Thus, routing decisions made by DOT do not examine many key indicators of risk (e.g., truck accident rates, potential property exposure, transit of environmentally and culturally sensitive areas, emergency response times, difficult to evacuate populations, bridges/tunnels, inclement weather, time-of-day transit, and high-hazards).
The Discussion Paper's Proposed Highway Routing Methodology does not rectify this major shortcoming. For pickup and delivery routes, the Discussion Paper chooses the shortest route. If, after discussions with state transportation departments, such a route is found incapable of handling the transport vehicle, the next shortest route is identified. In what appears to be a reversion to the "Decide and Defend" approach, the Discussion Paper identifies the last stage of the selection process:
Coordinate with local communities through which the pickup and delivery routes pass and provide an opportunity for local community comment and interaction on the final route selection. (P. 4)
The proposed methodology for selecting a "base" route segment (beyond the pickup and delivery routes) follows HM-164 by choosing the route with the minimum time in transit. "Optional HM-164 compliant routes" are evaluated in a three step process.
(1) Optional routes are examined to determine if transit times on such routes fall within some unidentified percentage of the "base" route (e.g., time in transit for the "base" route plus 10 percent). If no optional routes fall within the arbitrarily set percentage limit, then the base route is chosen.
(2) If optional routes remain after the first screen, then the total population along each such route and the "base" route are calculated. All routes which do not fall within some to-be-specified percentage of the population of the route with the fewest number of people are eliminated.
(3) If there is more than one route after the first two screens, then the number of miles of urbanized areas and the total population of the urbanized areas along the remaining routes are compared. The total urban population along the route is divided by the number of urban miles traversed to determine the potential population exposed along the transport corridor in urbanized areas. The route with the lowest urban population density value is selected.
No consideration would be given to any of the values listed in Table 2 Minimize truck accident rates; minimize the potential property exposure; minimize transit of environmentally sensitive areas; minimize emergency response time; avoid difficult to evacuate populations; minimize or eliminate transit of bridges and tunnels; minimize transit through inclement weather; and time-of-day travel restrictions. For example, the analysis should specifically include potential exposures to members of the public resulting from non-accident situations including truck refueling at truck stops, slow and/or stop-and-go traffic in road construction zones, and so-called "gridlock" incidents (up to 4 hours duration) resulting from traffic congestion, bad weather, accidents involving other vehicles, or other causes. of the Discussion Paper. Only populations within a set number of miles of the highway are considered. For example, dangerous terrain features, such as mountain passes, are ignored; seasonal inclement weather (blizzards and related road closures) are ignored; infrastructure inadequacies or man-made hazards along highways (such as buried natural gas pipelines, propane storage areas, etc.) are not considered; the availability or quality of emergency response is ignored; etc. In addition, no evaluation is made of the feasibility of mitigating dangers along the route.
While the limited routing methodology proposed in the Discussion Paper may be all that is feasible to do in cases of emergency, or possibly for one-time shipments by DOE, it is not adequate for shipping campaigns of 30 years or more in duration involving thousands of shipments. The Committee does not believe that such a routing methodology meets the commitment made in the 1986 Environmental Assessment for Yucca Mountain (and other sites under consideration at that time for a repository). For example, in volume III of Yucca Mountain EA, DOE said: "The DOE believes that the general methods and national average data used are adequate for this stage of the repository-siting process. Route-specific analyses and an evaluation of the impacts on host States and States along transportation corridors will be included in the environmental impact statement. The route-specific analyses to be performed in the future will proceed in the following sequence: (1) define important parameters; (2) gather data; (3) develop models as required; (4) perform analysis; (5) consider mitigating measures; (6) report results." Environmental Assessment Yucca Mountain Site, Nevada Research and Development Area, Nevada, Volume III, May 1986, p. C.2-37. Clearly, the highway routing methodology proposed in the Discussion Paper falls well short of meeting this commitment.
In addition, citizens along shipping corridors will not agree with the approach outlined in the Discussion Paper. They may be willing to accept a shipment under emergency conditions, provided that extraordinary precautions are taken. They may be convinced that they are on the least risk route for a major long-term shipping campaign and that all risk mitigation measures have been taken. They will not, however, accept a long-term shipping campaign which is not supported by the type of analysis and mitigation which the Committee believes is essential for NWPA shipments.
Recommendations
1. The Committee recommends that the Department of Energy adopt new procedures for selecting highway routes for shipments of spent fuel and high-level radioactive waste. These new procedures should replace those found in DOE Order 5632.11, Physical Protection of Unclassified Irradiated Reactor Fuel in Transit, 9-15-92.
2. The Committee recommends that the route selection process outlined in the Discussion Paper needs to be expanded to include factors other than time, distance, and urban populations. The routing methodology needs to include a more thorough assessment of the criteria listed in Table 2 DOT's list of primary and secondary route comparison factors (the Guidelines) address many, but not all of the hazards identified in this analysis. Most notably absent from the DOT Guidelines is mention of factors which may impede cask retrieval. Since nearly all NWPA transportation accidents are expected to be of the non-radiological variety, cask retrieval and subsequent reloading onto a cask transporter may prove to be a fundamental challenge faced by emergency responders., as well as:
High hazards that can potentially result in radiation levels or radioactive material releases in excess of regulatory limits Examples of high hazards found in the West that may challenge a cask's protective features include: (i) steep slopes and mountain passes where in an accident the velocity of a cask may increase significantly before the cask strikes a hard surface; (ii) thermal forces such as chemical and petroleum product storage tanks and pipelines situated adjacent to shipping routes; and (iii) impact and thermal forces working synergistically against a cask such as when a train derails or collides with another train prior to or after incurring thermal damage.; and
High hazards that can result in severe non-radiological accidents which create major problems. Examples of high hazard features which may cause and/or exacerbate non-radiological shipping accidents include: (i) inclement weather; (ii) routes bordered by inaccessible terrain; and (iii) weak infrastructure components.
Where high hazards are known to exist along potential western transportation routes, NWPA shipments should be rerouted to avoid such hazards. However, where it is not feasible to reroute shipments, special operational procedures such as reduced speed limits, severe weather protocols and time-of-travel restrictions should be adopted to reduce risk. Prudent planning in anticipation of spent fuel and HLW shipments through the West requires that high hazards along candidate routes be identified, evaluated and either avoided or mitigated.
3. The Committee recommends that DOE conduct route and mode-specific analyses of transportation impacts as part of the MPC EIS. The Committee made this recommendation to the Office of Civilian Radioactive Waste Management in January 1995. Comments of the High-Level Radioactive Waste Committee of the Western Interstate Energy Board on Notice of Intent to Prepare an Environmental Impact Statement for the Fabrication and Deployment of a Multi-Purpose Canister-Based System for the Management of Civilian Spent Nuclear Fuel, January 6, 1995. We reiterate this recommendation here because the MPC EIS would be an excellent opportunity to test highway and rail routing methodologies.
4. Finally, the Committee believes that the establishment of External Modal Working Groups (or other methods of securing stakeholder input) is a necessary step in the evolution of a routing strategy. Such Working Groups were proposed in DOE's Preliminary Draft Strategy for Development of a Route Selection Guidance Document for DOE Unclassified HRCQ Shipments (June 7, 1994). As we stated in our September 30, 1994 comments on the Preliminary Draft Strategy, we request that members of the WIEB HLW Committee be appointed to such Working Groups.
Analysis of Discussion Paper
The Discussion Paper correctly notes that the Department of Transportation has not established rail route selection regulations for shipments of spent fuel and HLW. DOE has developed a list of factors to be considered in selecting of rail routes, but the document provides little guidance on how these factors are to be considered. It should be noted that DOE has been criticized by the Department of Transportation for vagueness in its past rail route selection methodology for shipments from Three Mile Island to the Idaho National Engineering Lab. "During the course of planning the shipping campaign, DOE did not have well developed guidelines for route selection; the route selection process and the rationale for choosing the current route were not documented. (Review of the Selection of the Rail Route for Shipping Three Mile Island Debris, November 1989)
The Discussion Paper proposes a two-stage process for selecting routes. The first stage would be to determine which type of rail service -- general commerce or dedicated (including special) trains -- is to be used. Unfortunately, the Discussion Paper offers little guidance on how this decision will be made The decision process outlined in the Discussion Paper suffers from the same infirmities as DOT uncovered in its examination of the route selection process used for shipments from Three Mile Island to the Idaho National Engineering Lab. In its report, Review of the Selection of the Rail Route for Shipping Three Mile Island Debris (November 1989), DOT noted that the route "[s]election criteria were identified only as topics and were not explained in detail...About two years after the TMI route was chosen, DOE issued written guidelines for routing rail shipments. On August 28, 1988, the Transportation Management Division issued a memorandum...However, the level of definition remains as it was during TMI planning (i.e. topical listings only), and no rationale or ranking in order of imporance is provided to faciltate the inevitable tradeoffs among criteria." (Ibid.), stating only that:
Criteria for this determination will be based upon level of service required, institutional factors, cost, and other shipment- or campaign-specific considerations. (P. 3)
The Committee believes that safety should be a primary determinant of the type of rail service to be used. The Committee was hopeful that the dedicated train study which the Department of Transportation was mandated to do under the Hazardous Materials Transportation Uniform Safety Act would examine the relative safety of general commerce and dedicate trains. DOT has not completed the study.
Once the type of rail service has been determined, two methodologies for selecting routes are outlined -- one for general commerce train service and one for dedicated train service.
General Commerce: DOE would use "available tools to confirm the reasonableness" of the general commerce route selected by the rail carrier. There is no indication what are constitutes "reasonableness." The Discussion Paper adds:
Special programmatic or institutional issues may, at times, require specific route selection considerations. These should be discussed an negotiated on a case-by-case basis with the involved rail company. Issues that signficantly impact route selection, may require the use of a dedicated or special train.
The Committee is uncertain what is meant by the previous statement and urges DOE to focus on the relative merits, particularly those affecting safety, of general commerce and dedicated trains.
The Discussion Paper outlines a sequence of steps for identifying general commerce routes:
(1) Use a rail routing model In its analysis of DOE shipments from Three Mile Island to the Idaho National Engineering Lab, DOT concluded that, "[e]xisting rail routing models are not well suited to simultaneously handling multiple criteria objective functions. The ORNL [cited in the Discussion Paper] or ALK computer programs used were constructed to estimate how railroads would routinely route shipments. The routes they normall identify may not be appropriate for non-routine shipments for which there are several considerations. The models cannot address several criteria simultaneously to idetnify the optimal routess (i.e., the one that comes closes to meeting a combination of such routing objectives). The principal value of these models lies in providing limitedinformatin (e.g., wayside populatino) abut routes specified by the user or determined by the model." (Review of the Selection of the Rail Route for Shipping Three Mile Island Debris, November 1989) to determine a base route and "feasible alternatives", which are defined as alternative routes that have an impedance "Impediance" along a line is defined as a function of distance, mainline calassification, and number of railroads involved. Following is the impedance formula for DOE's INTERLINE rail routing program.
L = Min (i fi di) + (Tn)
i i
where
L = iimpedance for route;
i = railroad factor for link i;
i = 0.8 for the originating railroad
i = 1.0 for all other railroads
fi = mainline classification factor for link i;
fi = 1.0 for A-mainline
fi = 1.2 for B-mainline
fi = 1.9 for A-branchlines
fi = 4.0 for B-branchlines
di = distance along link i, miles;
Tn = transfer penality factor at node n. value within some percent of the impedance of the base route.
(2) Determine the population within some number of miles of the track along the base route and alternative routes and eliminate all routes that are more than some percent of the route with the lowest population.
(3) Talk to the railroad and if the railroad has a proposed route not evaluated above, then evaluate the railroad's alternative using the process outlined in steps 1 and 2.
(4) Negotiate with the railroad to find a route acceptable to DOE. If no agreement is reached on an acceptable route, DOE will consider dedicated or special train service.
(5) "If route selection issues can be adequately addressed within the context of general commerce operation, notify affected states of the route that will be taken and coordinate with the staes to address concerns that they have."
Dedicated (and Special) Trains: The Discussion Paper proposes a similar process for selecting dedicated train and special train routes. A rail model would pick a base route and feasible alternatives which have an impedance within a certain percentage of the base route. ("The parameters for dedicated or special train should differ from general commerce parameters by eliminating the originating railroad advantage and the penalty for rail system interchanges."). The population within a certain number of miles of the track of each route would be determined and those routes which did not fall within some percent of the population along the least populous routes would be eliminated. If more than one route exists after the population screen, the number of miles in urban areas traversed by each route and the number of people within so many miles of the track in those urban areas would be calculated. The population would be divided by the number of miles to determine potential population exposed in urbanized corridors. The route with the lowest urban population density value would be chosen.
The last step is to: "[n]otify the affected states on the route that will be taken and coordinate with the States to address concerns that they may have about the route, i.e., track quality. [As with the general commerce option, t]he Federal Railroad Administration can be brought in to inspect portions of the track that are of concern."
Thus, the proposed routing methodology uses five criteria:
Minimize distance to select the shortest route between origin and destination;
Minimize number of carriers and carrier interchanges;
Minimize the potential exposure by calcuating the population along a band on either side of the rail route; and
Minimize transit through urbanized ares to avoid high concentrations of population.
The proposed routing methodology does not consider:
Minimize time in transit;
Minimize cost of shipments;
Maximize the use of the highest track class;
Minimize the number of grade crossings;
Minimize accident rates measured by type of track, location or carrier;
Minimize emergency response time;
Minimize the potential property exposure;
Minimize the transit through environmentally sensitive areas;
Minimize the transit through culturally sensitive areas; or
Consider class of railroad.
It is not possible to adequately evaluate the proposed two step process --decide first whether shipments will be by general commerce or dedicated train and then evaluate the route -- until there is a better understand the decision criteria proposed for determining whether general commerce or dedicated trains will be used. For example, if DOE decides that spent fuel should be shipped by general commerce trains -- trains which can spend days sitting in rail marshaling yards during a cross country trip -- then time in transit may become a very important routing criterion. If DOE chooses to use dedicated trains the differences in transit times among competing routes are likely to be smaller and thus other factors, such as population exposure would take on relatively greater importance.
The proposed routing methodology does not consider many important factors and seems to be crafted around the limited capabilities of existing rail routing models. The Committee does not believe that the routing methodology proposed in the Discussion Paper meets the commitment made in the 1986 Environmental Assessment for Yucca Mountain (and other sites under consideration at that time for a repository). For example, in volume III of Yucca Mountain EA, DOE said: "The DOE believes that the general methods and national average data used are adequate for this stage of the repository-siting process. Route-specific analyses and an evaluation of the impacts on host States and States along transportation corridors will be included in the environmental impact statement. The route-specific analyses to be performed in the future will proceed in the following sequence: (1) define important parameters; (2) gather data; (3) develop models as required; (4) perform analysis; (5) consider mitigating measures; (6) report results." Environmental Assessment Yucca Mountain Site, Nevada Research and Development Area, Nevada, Volume III, May 1986, p. C.2-37. Clearly, the highway routing methodology proposed in the Discussion Paper falls well short of meeting this commitment.
Citizens in shipment corridor states will not agree with such an approach. They may be willing to accept a shipment under emergency conditions, provided that extraordinary precautions are taken. They may be convinced that they are on the least risk route for a major long-term shipping campaign and that all risk mitigation measures have been taken. They will not, however, accept a long-term shipping campaign which is not supported by the type of analysis and mitigation which the Committee believes is essential for NWPA shipments.
Recommendations
1. The Committee recommends that the Department of Energy adopt new procedures for selecting rail routes for shipments of spent fuel and high-level radioactive waste. These new procedures should replace those found in an August 29, 1988 memo entitled, Current Recommended Practice For DOE Rail Routing Of Unclassified Spent Nuclear Fuel (SNF) and High Level Waste (HLW). Current procedures are vague and insufficiently rigorous to support the type of major shipping campaign envisioned under the NWPA.
2. The Committee recommends that DOE's next interation of the Discussion Paper include a clear explanation of the criteria that are proposed to be used in determining whether general commerce or dedicated trains (including special trains) will be used.
3. A primary criterion for deciding whether to ship by general commerce train or dedicated (including special) train must be relative safety of the shipments. If DOT's pending dedicated train study, which was mandated by the Hazardous Materials Transportation Uniform Safety Act, fails to address safety issues when evaluating general commerce and dedicated trains, DOE should conduct such a safety evaluate for its shipments. For example, DOE should examine: the relative transit times for NWPA casks using general commerce and dedicated trains (transit times affect routine radiological exposure as well as emergncy preparedness); security and safeguard measures feasible in general freight and dedicated trains; and consequences of accidents (both radiological and the difficulty of train and cask recovery) involving general freight and dedicated trains. For NWPA shipments, which involve large quantities of material over 30 years or more, DOE should examine the optimal length of a dedicated train and the use of intermodal transfers from truck to rail, both for Multi-Purpose Canisters and GA 4/9 truck casks.
4. The rail routing model cited in the Discussion Paper was found to be seriously lacking by the Department of Transportation (it cannot address several criteria simultaneously to identify the optimal route). The Committee recommends that DOE not base its decision on a rail routing methodology on whatever rail routing modeling capability is on the shelf. Future routing models must be capable of using routing specific data (such as accident rates) and all assumptions need to be justified. For example, there is no analysis justifying the assumption in the Interline Model that B-branchlines have an impediance value four time that of A-mainlines. Instead of such generic assignments of impediance values to track classification, the model should accommodate route specific data. Such an approach to a shipping program involving 43 states over 30 years, as would be the case for NWPA shipments, will clearly not be acceptable to the public.
5. The Committee recommends that the route selection process outlined in the Discussion Paper needs to be expanded and more thoroughly assess the criteria listed in Table 2 Table 2 lists: minimize time in transit; minimize cost of shipments; maximize the use of the highest track class; minimize the number of grade crossings; minimize accident rates measured by type of tract, location or carrier; minimize emergency response time; minimize the potential property exposure; minimize the transit through environmentally sensitive areas; minimize the transit through culturally sensitive areas; and consider class of railroad., as well as:
High hazards that can potentially result in radiation levels or radioactive material releases in excess of regulatory limits Examples of high hazards found in the West that may challenge a cask's protective features include: (i) steep slopes and mountain passes where in an accident the velocity of a cask may increase significantly before the cask strikes a hard surface; (ii) thermal forces such as chemical and petroleum product storage tanks and pipelines situated adjacent to shipping routes; and (iii) impact and thermal forces working synergistically against a cask such as when a train derails or collides with another train prior to or after incurring thermal damage. Examples of high hazard features which may cause and/or exacerbate non-radiological shipping accidents include: (i) inclement weather; (ii) routes bordered by inaccessible terrain; and (iii) weak infrastructure components. ; and
High hazards that can result in severe non-radiological accidents which create major problems. For example, DOE should examine cask retrieval capabilities along potential. Since nearly all NWPA transportation accidents are expected to be of the non-radiological variety, cask retrieval and subsequent reloading onto a cask transporter may prove to be a fundamental challenge faced by emergency responders.
Where high hazards are known to exist along potential western transportation routes, NWPA shipments should be rerouted to avoid such hazards. However, where it is not feasible to reroute shipments, special operational procedures such as reduced speed limits, severe weather protocols and time-of-travel restrictions should be adopted to reduce risk. Prudent planning in anticipation of spent fuel and HLW shipments through the West requires that high hazards along candidate routes be identified, evaluated and either avoided or mitigated.
6. The Committee recommends that DOE conduct route and mode-specific analyses of transportation impacts as part of the MPC EIS. The Committee made this recommendation to the Office of Civilian Radioactive Waste Management in January 1995. Comments of the High-Level Radioactive Waste Committee of the Western Interstate Energy Board on Notice of Intent to Prepare an Environmental Impact Statement for the Fabrication and Deployment of a Multi-Purpose Canister-Based System for the Management of Civilian Spent Nuclear Fuel, January 6, 1995. We reiterate this recommendation here because the MPC EIS would be an excellent opportunity to test highway and rail routing methodologies.
7. Finally, the Committee believes that the establishment of External Modal Working Groups is a necessary step in the evolution of a routing strategy. Such Working Groups were proposed in DOE's Preliminary Draft Strategy for Development of a Route Selection Guidance Document for DOE Unclassified HRCQ Shipments (June 7, 1994). As we stated in our September 30, 1994 comments on the Preliminary Draft Strategy, we request that members of the WIEB HLW Committee be appointed to such Working Groups.