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Nuclear Waste Transport 135 diation.129 Trucks transporting TRU to WIPP were involved in three accidents between 1999 and 2005, again without any release of radioactivity.130 Several incidents of minor radioactive releases from SNF transportation accidents were reported prior to 1984, but changes in waste packaging designs since then have reduced the risk of similar incidents occurring.131 A significant number of releases from transportation of LLW prior to 1985 have also been reported.132 Notwithstanding the overall positive record, the NAS Committee on Transportation of Radioactive Waste cautioned that any large-scale transport of SNF to a repository or of SNF to a consolidated storage facility would represent a major increase in shipments and a commensurate challenge. The committee reported that estimated shipments of SNF to Yucca would be twenty times the total number of SNF shipments made in the United States before 2006. It stated that these shipments would be primarily by rail; the number of planned rail shipments to Yucca would be eighteen times the number of rail shipments that occurred up to 2006. The committee estimated that HLW shipments to a repository, which would be in addition to the estimated SNF shipments, would comprise about a fifth of the total shipments to the facility.133 The NAS committee noted that transport of SNF to the planned interim private fuel storage (PFS) facility in Utah would also be a major undertaking, involving an estimated thirteen times as many SNF shipments as had taken place up to 2006 in the United States.134 The site of the planned facility does not have access to rail. PFS transport plans provided for shipment of SNF in NRC-approved containers by dedicated rail from reactor sites or other points of origin to an “intermodal transport facility” (ITF) twenty-four miles from the PFS facility, where the containers would be transferred to heavy-haul trucks for transportation to PFS. Two dedicated trains would arrive at the ITF weekly, and two to four truck shipments of SNF would be needed weekly between the ITF and PFS.135 The federal government has thwarted efforts by PFS to obtain transportation rights-of-way over federal lands in order to reach its facility. A planned rail access route across public lands was precluded when Congress included the relevant lands in a wilderness area designation. The Bureau of Land Management then denied a right-of-way for construction of the ITF and truck access to the PFS site on the ground, among others , that its own EIS on the proposal was inadequate. DOI’s Bureau of Indian Affairs also refused to approve the Goshute tribe’s lease of its land for the facility to PFS. However, the U.S. District Court for the District of Utah vacated and reversed DOI’s decisions in July 2010, finding DOI’s actions arbitrary and capricious;136 only time will tell whether the facility will ever come to fruition. Transportation of TRU for Disposal at WIPP The shipment of TRU wastes to WIPP represents the largest-scale U.S. program thus far for shipment of highly radioactive wastes. Given that there have been few accidents and no transportation-related releases of radiation documented since shipments of TRU began in 1999, the NAS Committee on Transportation of Radioactive Waste regards the WIPP transportation program as successful.137 The program may thus provide some lessons for meeting the challenges involved in future shipments of SNF and HLW to repositories or consolidated storage facilities. However, the NAS committee identified a number of important distinctions between issues raised by transportation of TRU to 136 Fuel Cycle to Nowhere WIPP and issues that would be encountered in transport of SNF and HLW to one or more repositories, and cautioned that these distinctions may limit the relevance of the WIPP transportation program experience. These include differences in support by the host and transit states; number of routes used for shipments; mode of transportation (TRU is being trucked to WIPP, whereas DOE has planned to ship SNF and HLW to a repository by rail); and the volume of material to be transported.138 As noted earlier , WIPP received 9,207 truck shipments of TRU from 1999 to December 2010.139 In comparison, more than 50,000 truck shipments of SNF and HLW would be required to fill the Yucca repository to capacity over its twenty-four-year operational period.140 Also, SNF and HLW shipments generally consist of more highly radioactive material than do shipments of TRU...

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