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Presentation to the National Academy of Sciences -- "Irradiated Fuel Transport to Yucca Mountain: What History Tells Us"

Michele Boyd, Legislative Representative for Public Citizen
Presented at the NAS Committee on Transportation of Radioactive Waste

May 5, 2004

I would like to thank the committee for giving me the opportunity to comment briefly on what past experience with transporting irradiated fuel tells us about the proposed Yucca Mountain transportation program.

My main message is that the transport of 70,000 metric tons of the country's high-level radioactive waste and irradiated fuel to one national site would be completely unlike past radioactive waste shipments in the United States. The magnitude and duration of this proposal is outside current the realm of experience. More waste would be shipped in the first year alone than as been shipped in the US in the last three decades.

I urge this committee to closely examine all of the various aspects of this proposal, not just the historical numbers. In order to the protect public, all of the various aspects of transportation, such as human error, chance, deliberate sabotage, and cask integrity, must be carefully considered. Simply extrapolating from past experience – the statistics of which are disputable – will not be sufficient to ensure that these shipments will be safe, and certainly will not convince the public that they are.

What do the numbers tell us?

In short, the historical data tell us that experience in the United States transporting this waste by rail over long distances, as DOE is planning, is limited. Particularly in the past decade, there have been very few shipments involving relatively small amounts of irradiated fuel over very short distances. Most of the 3,025 shipments in the United States over the past 40 years took place from the 1970s to the mid-1980s. Since then, the number has drastically decreased. Between 1988 and 1995, 177 shipments of irradiated fuel were made in the US, 61% of which were by truck. In 1996 and 1997, there were 28 shipments.[1] In 2001, there were 3 shipments.[2]

In comparison, under the "mostly rail" national plan that DOE has selected, there would be more than 22,000 shipments by rail and truck and almost 3,000 barge shipments over 38 years, averaging out to about 658 shipments per year.[3] At sites that do not have rail access, DOE plans to ship thousands of casks by barge through densely populated cities, such as Boston, Baltimore, Newark, and Miami.[4] In addition, more of the shipments to Yucca Mountain would occur over longer distances than in the past. Between 1979 and 1997, 82% of the truck shipments were less than 900 miles, while 80% of the rail shipments were less than 600 miles.[5]

Depends what "accident" means

Despite having relatively small numbers of high-level radioactive waste shipments to deal with, and many months of lead time to make preparations, DOE and its contractors have made serious mistakes that fortunately – by chance – did not result in serious accidents. For example:

• From 1986 to 1990, DOE transported almost two dozen train shipments of Three Mile Island Unit 2 fuel debris from Pennsylvania, through St. Louis, to Idaho. DOE violated agreements with St. Louis officials about speed limits and avoiding rush hour. One shipment collided with a car stalled on the tracks. Another shipment included buffer cars mistakenly marked with hazardous, flammable chemical placards that would have prevented fire fighters from using water to put out flames in the event of a fire, risking overheating and potential failure of the irradiated fuel casks. Another shipment rolled out of control during a locomotive transfer until a rail worker was able to chase it down and apply manual brakes.[6]
  
  
• In 2001, DOE only shipped three truck casks of high-level waste the entire year from South Carolina to Idaho. DOE broke its promise to Missouri by changing its route to travel through the state. Then, the convoy showed up on the Missouri border at rush hour and failed to designate an official safe stopping area in the event of an emergency. Rather than pulling over to wait out the severe weather, the convoy travelled through a thunderstorm.[7]

Low-level waste shipments made by DOE also indicate the type of potential problems facing Yucca Mountain transport. For example,

• Last year, DOE shipped a reactor vessel from Michigan to South Carolina. Within the first day, an axle on the heavy haul truck broke and four tires had to be removed. As a result, the reactor was parked overnight at a truck stop only 100 yards from a gas station that is a children's school bus stop. After travelling by rail to Toledo, Ohio, it was determined that British Nuclear Fuels (BNFL), the company managing the shipment, failed to properly complete the necessary paperwork to transfer to another rail line, so it had to sit on the rail line overnight. Two days after the shipment passed through Michigan, a train derailed on the same tracks, possibly due to the extreme weight of the reactor vessel.[8]

These types of errors need to be evaluated in the context of a massive transportation program involving multiple truck shipments per day and multiple train shipments per week over a period of at least 24 years.

Accidents are inevitable

Accidents involving irradiated fuel shipments would be inevitable. The uncertainties involved in nuclear waste transport means that it is extraordinarily difficult to plan for every contingency. Take, for example, three major non-nuclear accidents this year alone:

• Baltimore highway accident: On January 13, a truck driver had a heart attack on I-895 outside of Baltimore. The truck that he was driving veered off the overpass, dropping 60 feet onto 1-95 below and bursting into flame.[9]
  
  
• Connecticut tanker truck: On March 26, a tanker truck carrying home-heating oil struck a concrete barrier on 1-95 in Connecticut and exploded. The truck burned for two hours at 1,800 degrees Fahrenheit and melted the overpass. The accident was caused by a car swerving into the truck, which caused the truck to scrape a concrete barrier and split the side of the tank.[10]
  
  
• Texas train accident: Just this past Monday, May 3, two trains collided head-on on a bridge in Texas, sending two locomotives, 5 freight cars, and 5,600 gallons of diesel fuel hurling into the San Antonio River. The cause of the derailment is unknown at this time.[11]

In fact, as the number of shipments increase, the human factor will play a larger role in accidents. The more commonplace an activity becomes, the more likely that there will be decreased vigilance on the part of everyone involved.

Terrorism threats remain

In addition to accident risks, transporting high-level nuclear waste across the country through highly populated areas poses a security risk. DOE and NRC testing has found that truck casks are vulnerable to sophisticated antitank weapons and high-energy explosive devises, which can breach the wall of the cask. But, as the “backpack” bombings in Madrid on March 11 show, it does not take a sophisticated missile to successfully attack a train or train tracks. Does DOE intend to have the thousands and thousands of miles of track policed? According to testimony by former Under Secretary of Energy Robert Card at the House Energy Committee hearing on March 25, DOE does not even intend to conduct a specific examination of the Madrid train bombings in developing its transportation security plan.

Other regulatory agencies that are supposed to be involved in regulating the transport of high-level waste should also be examining these threats. According to the General Accounting Office (GAO) testimony on March 23 before the Senate Committee on Commerce, Science, and Transportation, “The lack of clearly delineated roles and responsibilities [between the Transportation Security Administration and the Department of Transportation] could lead to duplication, confusion, and gaps in preparedness.” (Emphasis added.) The DOE, Transportation Security Administration, Department of Transportation, and NRC should assess the Madrid bombings and determine what types of security measures would be need to protect shipments of irradiated fuel to Yucca Mountain.

Are the casks up to the job?

The bottom line is that accidents involving nuclear waste shipments to Yucca Mountain will happen if there are shipments. Ultimately, the robustness of the shipping casks will determine whether radioactivity is released when there is an accident. Yet, the NRC does not require full-scale testing as part of its certification process. None of the casks that are now used in the United States have undergone full-scale testing. And there are no plans for full-scale testing of the casks that could be used for waste shipments to Yucca Mountain. In fact, the DOE and the nuclear industry oppose full-scale testing. This certainly does not inspire public confidence.

Even with full-scale testing, casks may not perform as expected in the event of a severe crash. DOE accident analyses fail to consider the statistical likelihood of manufacturing and human error and its impact on cask performance. Oscar Shirani, the former lead quality assurance inspector for Exelon, found major quality assurance violations in the Holtec storage/rail transport cask and concluded that the structural integrity of the casks were questionable. Moreover, the NRC's performance requirements for nuclear waste casks were established in the 1970s. They seriously underestimate the worst-case accident scenario possible today. For example, the drop test, which simulates a crash at 30 miles per hour (mph), does not take into account that nuclear waste shipments are not required to travel at 30 mph or less. The burn test requires that casks can withstand an engulfing fire at 1,475 degrees Fahrenheit for 30 minutes, but the 2001 Baltimore train tunnel fire burned at 1,800 degrees for at least three hours.

Moreover, the DOE is not requiring that older fuel rods, which have been cooling the longest, be shipped first. After 5 years, irradiated fuel has a surface dose rate of 46,800 rem per hour. After 10 years, the surface dose rate is 23,400 rem per hour, which can still cause death within less than 2 minutes of exposure.[12]   In its FEIS, DOE assumed that the casks would contain 14 to 15-year-old irradiated fuel for its accident consequence analysis.[13]

Finally, the Association of American Railroads maintains that irradiated fuel should be shipped in dedicated trains that only transport radioactive materials.[14] Yet, current DOT regulations allow the shipment of irradiated fuel casks in mixed freight trains. This decision needs to be reconsidered.

What about truck casks on rail lines?

On April 5, DOE announced that it will use “mostly rail” to transport irradiated fuel to Yucca Mountain nationally and within Nevada. Nonetheless, DOE has acknowledged that the Nevada rail corridor is unlikely to be completed by 2010 – its unrealistic target date for starting shipments. On March 10, DOE issued a memo evaluating the possibility of transporting the waste in truck casks by rail to Nevada, where they would be transferred to light-weight trucks for shipment to Yucca Mountain, for the first six years of shipments. This is the same proposal that was rejected in the FEIS as “not practical.” According to DOE, the truck-casks-on-railcars scenario would cost an additional $1 billion and “would lead to the highest estimates of occupational health and public hearth and safety impacts, most coming from the rail-traffic related facilities.”[15]

In its March memo, DOE concluded that using legal-weight truck casks transported by rail is not a substantial change from its original scenario. This conclusion is incorrect. Although none of these casks have been built yet, the conceptual designs minimize the thickness of shielding in order to contain more waste and still be within weight limitations. This means that the casks are less robust than the rail/barge casks. According the State of Nevada, a truck cask on a rail car in the 2001 Baltimore train tunnel fire would have failed in a few hours.[16] Moreover, the FEIS analysis of the “mostly rail” scenario considered rail casks that would carry six times more waste than can be contained in a legal-weight truck cask.[17]   The plan to use the legal-weight truck casks means that more shipments will be required. This is a significant change and should be fully analyzed.

International experience: not the model to strive for

While the nuclear industry often points to international transport as the exemplary model for the U.S., nuclear waste transportation internationally has a tarnished history. For instance, it was revealed in 1997 that 26% of the French transport casks were contaminated 50 times above the regulatory dose limits on their exterior surface.[18]   Such contamination incidents also took place with UK, German, and Swiss shipments.[19]  As a result, shipments between France and Germany were halted for 3 years, from 1998 to 2001.[20]

Moreover, high-level radioactive waste transportation in Europe has been the object of extensive public opposition. In Germany, mass protests have slowed high-level waste shipments to a trickle, and long-delayed opening of the underground burial facility. The German government and nuclear power industry had hoped to have many hundreds or even thousands of high-level waste containers delivered to and buried at Gorleben by now. But in the past 25 years, only a couple dozen containers have made it to an “interim” storage warehouse near the proposed burial site.[21] The proposed dump has been indefinitely postponed due to the intense local and national opposition. Similar non-violent mass protest movements in Italy and South Korea successfully stopped planned dumps long before any trucks, trains or barges even arrived carrying high-level waste.

The Public's Legitimate Concerns About Risk

Most people do not like or trust radioactive material and will be extremely critical of plans to ship it along their highways and railroads. This matters and should not be summarily dismissed as illegitimate because the public "does not understand" the concept of risk. The nuclear industry claims that they are not being allowed their "piece of the risk space." But why are people obligated to increase the total risk space to let them in? Given that people are willing to accept only a certain total risk, what risk is going to be removed to make this particular risk acceptable?

Conclusion

I would like to address the argument often made that consolidating all of the high-level radioactive waste in one place will make the country more secure. As long as we continue to produce irradiated fuel, then all of the waste can never be consolidated in one location.

If the plans for the Yucca Mountain site go forward, thousands of containers of irradiated fuel will move throughout the country on roads, rails, and barges for at least 24 years, mostly likely longer. Once Yucca Mountain is full, DOE has estimated that there will be approximately 42,000 metric tons heavy metal of commercial irradiated fuel at 63 sites in 31 states, which about same amount of waste at most of the same sites as there is now.[22] At the same time, the push for Yucca Mountain is being used as an excuse to make plans to build more reactors in the United States, which means that we will continue to produce waste, possibly at new sites. Therefore, high-level waste will continue to be sitting at every reactor site; waste will be transported by rail, truck, and barge throughout most of the country; and waste will be located at Yucca Mountain. This is hardly the definition of “consolidation.”

Irrespective of whether truck, rail, or barge shipments are used, public health and safety will be placed at risk and it is imperative to acknowledge and fully evaluate these risks. I would like to close by again urging the committee to fully examine the multiple risks, such as increased human error, terrorism and cask integrity, associated with transporting large volumes of high-level and irradiated fuel over long distances.

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