FRA Certification Helpline: (216) 694-0240

(The following story by Carl Prine appeared on the Pittsburgh Tribune-review website on July 26.)

PITTSBURGH, Pa. — Federal Railroad Administration spokesman Steven Kulm answers questions posed by the Trib about proposed nuclear shipments through Pennsylvania.

Question: What safeguards are put in place to ensure safe transit of spent nuclear fuel or other atomic shipments through heavily populated areas, such as Pittsburgh?

Answer: Extensive regulations currently exist that address the safe and secure transportation of radioactive materials. U.S. DOT regulations contained throughout 49 CFR Parts 100 to 185 already address hazard communication, the type of packaging allowed for the transport of this material, proper preparation of the package for transport, radiation level limitations and recently, even rail routing requirements for Spent Nuclear Fuel (SNF) and High-Level Radioactive Waste (HLRW). These regulatory requirements are largely based on International Atomic Energy Agency (IAEA) safety standards. In addition, taking a proactive approach to railroad safety, FRA recognized the need to enhance its inspection policy and procedures for the transport of SNF and HLRW by rail to ensure that the railroad industry’s outstanding safety record for moving nuclear material shipments continues unabated despite the significant increase in nuclear materials shipments. In regard to the shipments of SNF from the Three Mile Island (TMI) reactor in the late 1980’s, FRA developed and applied an inspection policy focusing available resources for the TMI shipments to ensure safe and secure rail transportation of them. In 1998, FRA updated this already existing policy and developed the Safety Compliance Oversight Plan (SCOP) for transportation of SNF and HLRW, which set forth enhanced FRA procedures to specifically address the safety of these rail shipments. FRA believes this policy is necessary to ensure the safety of future rail shipments of SNF and HLRW which are predicted/expected to increase significantly irrespective of the use of Yucca Mountain to permanently store such materials.

Click here (http://www.fra.dot.gov/us/printcontent/1659) to read the April 25, 2002 testimony by former FRA Administrator Allan Rutter before the House Transportation and Infrastructure Committee that describes in more detail the role of FRA in overseeing rail shipments of SNF and HLRW and the measures included in the SCOP.

Q: Although DOE distanced itself a bit in the report by suggesting that these routes are not final, they certainly are the fastest and safest lines available for the transportation of nuclear waste material, and in the case of the CSXT/Norfolk-Southern lines that converge in Allegheny County, the pathway used before for similar shipments. Is there a possibility that DOE could change these routes? What input would be needed from Pittsburgh, where the city council president has said he would like to explore ways to reroute the material around Allegheny County?

A: SNF and other high-level radioactive material shipments are covered by the new Interim Final Rule on Rail Hazmat Routing issued by the U.S. DOT Pipeline and Hazardous Materials Safety Administration and published on April 16, 2008 (see attached summary document and full text). Under these regulations, railroads are required to perform a comprehensive and methodical safety/security risk analysis to determine the safest and most secure route to move the most dangerous hazardous materials and then implement that selected route by September 1, 2009. In collecting the relevant data for analysis, each railroad will seek to obtain information from state and local officials regarding security risks to high-consequence locations along or in proximity to those routes. Under the rule, railroads are to collect this and other data starting July 1, 2008, to be used to conduct a safety/security risk analysis of the preferred route(s) currently used, and the potential hazards and risks affecting potential alternate routes. In addition, the rule requires railroads to use a minimum of 27 specific risk factors as part of their safety/security risk analysis.

Q: Adding up the amount of nuclear fuel and highly radioactive waste to be shipped out of the facilities that feed, by rail, into the Pittsburgh train corridor, it would see that DOE plans to ship about 7,000 metric tons of the stuff over a 24 year span, perhaps doubling this amount if the program continues into 2067. What is the risk of sabotage, accident or background radiation affecting the citizens of Allegheny County as these shipments roll through?

A: We recommend you speak with DOE, the Department of Homeland Security, the Transportation Security Administration, and the Federal Bureau of Investigations regarding your interest in the risk of sabotage. However, it is worthy to note that the Interim Final Rule on Rail Hazmat Routing includes a provision to guard against the possibility that an unauthorized individual could tamper with rail cars containing hazardous materials to precipitate an incident during transportation, such as detonation or release using an improvised explosive device (IED). Starting July 1, 2008, railroads are now required to include as part of their standard pre-trip inspections of placarded hazardous material rail cars an inspection for signs of tampering with the rail car, including its seals and closures, and an inspection for any item that does not belong, is suspicious, or may be an IED.

FRA believes that the risks to the general public anywhere along a rail route used is extremely low given the high degree of integrity of the Nuclear Regulatory Commission (NRC) certified packaging used to transport this material, the extremely safe and secure transportation history of shipments of this material by rail over the past 50 years, the high level of ongoing attention and coordination among the parties involved (State/Federal/Railroads) for the preparation and eventual transport of this material in the future using Dedicated Trains, and the commitment of the federal agencies involved to apply stringent and comprehensive safety and security standards to the planned shipments.

Q: Critics have speculated that the costs of cleaning up an accident involving one of these shipments could top $10 billion. What is a more likely price-tag?

A: FRA does not estimate ‘clean up’ costs and is not in a position to evaluate the accuracy or veracity of the $10 billion figure you cite from thus far unidentified critics. We assume you are speaking with these critics and are asking for their supporting materials and are diligently reviewing all of their assumptions and methodology.

Q: The State of Nevada’s nuclear people suggest that an incident involving one of these shipments could create anywhere from 13 to 40,868 latent cancer deaths. What is FRA’s perspective on these numbers? What is a more realistic number, in your opinion, of latent cancer deaths in a highly urbanized environment due to a rail or truck incident?

A: This question is directed to DOE, not FRA. However, the March 2005 FRA report entitled Use of Dedicated Trains for High-Level Radioactive Waste and Spent Nuclear Fuel discusses the types of trains that could be used to transport the SNF and the potential risks associated with four different rail accident scenarios.

Q: Some critics believe that a “worst case scenario” for a SNF container would be to submit it to “a long-duration, high-temperature fire that would engulf a cask.” Something, perhaps, like the Baltimore Rail Tunnel fire of 2001. What would happen to one of these casks should it endure conditions akin to that described above? Is it possible to test, redesign and manufacture a different sort of cask before it is time to begin shipping the materials to Yucca Mountain?

A: The DOT regulations require the use of Nuclear Regulatory Commission (NRC) certified packages for SNF or other high-level radioactive materials for transportation. We recommend that you contact the NRC Office of Public Affairs for additional information.

Q: Critics have suggested that the best safety measure DOE could take would be to ship the oldest fuel first and to transport only that fuel which has passed its half-life (depending, of course, on the materials being sent). What is FRA’s perspective on this?

A: FRA has no role in that deliberation and takes no position on the subject.

Q: The TMI shipments that passed through Pittsburgh until 1990 engendered a great deal of concern, even public protests. What lessons did FRA learn from the shipments from TMI to Idaho? Were they incident free? Did the public outcry change the way you have approached the Yucca Mountain transportation strategy?

A: The FRA first developed and applied its focused inspection policy for the TMI shipments to ensure safe and secure rail transportation of them and that policy, in its updated and expanded form (the SCOP) has been and will continue to be applied by the FRA to rail shipments of SNF and HLRW, including those planned to be transported to Yucca Mountain. The SCOP is a “living document” that the FRA will continue to periodically update and modify as new developments occur and this process includes solicitation of comments and feedback from States, other Federal agencies, rail carriers and rail unions.

Q: The Brotherhood of Locomotive Engineers and Trainmen (BLET) has a number of issues with the proposed plans to ship nuclear waste to Yucca Mountain. They include the fact that rail workers won’t have a choice of these assignments, leading to concerns that a pregnant woman either in the yard or on a train would be forced to handle this material. BLET believes that there should be a formal certification process in place so that only well-trained trainmen end up hauling or directing the movement of this freight. What is FRA’s perspective on this?

A: Under existing provisions of federal rail safety regulations, locomotive engineers are trained and certified to perform the most demanding service their job requires and already operate trains hauling SNF, HLRW, and other types of hazardous materials. If BLET believes some of its members do not meet current federal certification requirements, FRA is interested in having them identified for us so we can take appropriate action.

Furthermore, some of the federal regulations and policies that will govern Yucca Mountain shipments include: safety briefings for train crews to ensure they implement basic ALARA (As Low as Reasonably Achievable) radiation protection principles of time (minimizing), distance (maximizing) and shielding; the use of buffer cars to increase distances between the locomotive or other personnel cars and the rail cars holding the SNF or HLRW packages to render radiation levels in those occupied locations to below normal background radiation; and the use of Dedicated Trains to provide virtual run-through service to greatly minimize stop and dwell times along the selected route.