The committee outlines two types of concerns over the Department of Energy’s National Nuclear Security Administration’s (DOE-NNSA’s) conceptual plans to ship, receive, and emplace surplus plutonium in the Waste Isolation Pilot Plant (WIPP). The first—discussed in this chapter—are implementation challenges, which by the committee’s definition, are related to the execution of the plan and include serious concerns about the plan’s duration, proposed schedule, and workforce. The second are system vulnerabilities, which have larger consequences if not addressed, and are discussed in Chapter 5. Specific implementation challenges discussed below are grouped by early development challenges and long-term sustainability challenges.
DOE-NNSA has developed conceptual plans for the dilute and dispose program. It is expected that those plans as well as the specific operational plans at the various sites will continue to evolve as they mature. The early stage of DOE-NNSA’s dilute and dispose plans introduces uncertainty and a lack of fidelity in the details, which the committee recognized. The assessment below of the plan introduced in the previous chapter provides a high level review and guidance to be used as the plans are further developed. Several implementation challenges are identified that are likely to affect the plan’s schedule and cost.
In summary of the plan, DOE-NNSA’s mission to dilute and dispose of 34 metric tons (MT) of surplus plutonium material is justified by the United States’ commitment to non-proliferation and the disposition of its inventory of declared surplus weapons material (DOE-NNSA, 2018).1 The current plan was developed and is managed by the Defense Nuclear Nonproliferation office within DOE-NNSA. The plan indicates emplacement operations to be completed in fiscal year (FY) 2049, with 7 years of schedule contingency, bringing the probable completion to FY 2056, as calculated by the U.S. Army Corps of Engineers (USACE) at a 70 percent confidence level (see Figure 3-1). The operations and processes described in the plan span four DOE sites (see Figure 3-2); the transportation of materials and transuranic (TRU) waste will affect at least seven different states. The plan includes details on the amount of material that will be processed and the volume of TRU waste that will be created. Details of scaling up of existing processes to meet the schedule outlined above are described and include increases in personnel and equipment to allow factors of ~15 or more increases in throughput rates.
DOE-NNSA’s dilute and dispose program has assessed cost and schedule risk through a process defined by the Government Accountability Office (GAO) and has produced a Life-Cycle Cost Estimate (LCCE) estimating that the full life-cycle cost of the dilute and dispose program will be $18.2 billion (in FY 2017 dollars; SRNS, 2018a). A Risk and Opportunities Management Plan (SRNS, 2018d) and a Risk and Opportunities Analysis Report (ROAR; SRNS, 2018e) are included as part of the LCCE package of documents. Many of the highest assessed cost and schedule risks are related to equipment failure or lack of qualified personnel. As stated previously, the committee did not independently verify the stated frequency of realized cost and schedule risks such as unplanned process excursions, equipment breakdowns, or accidents that were used by DOE-NNSA to determine programmatic risks to cost and schedule. Based on the lack of maturity of some of the processes involved, there is some concern over the accuracy of the quoted failure rates.
1 Adherence by the United States and the Russian Federation to the Plutonium Management and Disposition Agreement is currently uncertain—and is discussed in the next chapter.
In the discussion that follows, implementation challenges are described and are grouped as, first, early program development challenges and, next, as sustainability challenges. As defined by the committee, implementation challenges are related to the execution of DOE-NNSA’s plan and include serious concerns about the plan’s duration, proposed schedule, and workforce. System vulnerabilities, discussed in Chapter 5, consider DOE-NNSA’s plan in the context of broader system issues across the DOE complex and question its approach, assumptions, and motivation which could ultimately threaten the successful, full completion of the program.
DOE-NNSA’s dilute and dispose plan for operations makes use of existing facilities and previously developed processes which reduces technical risk to and cost of the program. Figure 4-1 shows the process steps described in Chapter 3 and how they map to various existing DOE capabilities (the different programs are shown by different colors in the figure). Scaling-up details are also captured. In addition to operations, DOE-NNSA’s plan includes management actions such as National Environmental Policy Act analysis and permit modification requests. Details of how DOE-NNSA plans to achieve International Atomic Energy Agency (IAEA) inspections and verification with a target date of FY 2023, as shown on the Master Schedule and included as a requirement for disposal (DOE-NNSA, 2018), are absent in the other documents that the committee received.2
As shown in Figure 4-1, there is prior experience within DOE for nearly all of the individual processes described in DOE-NNSA’s dilute and dispose planning documents. However, the full dilute and dispose plan has not yet been demonstrated from start to finish. This is a concern because even well-established capabilities run into unforeseen problems when integrated. Furthermore, DOE’s experience with some of the dilute and dispose processes and their demonstrated baseline values are not well established. For example, one could assume that few pits have been processed and shipped to Los Alamos National Laboratory (LANL) beyond pilot demonstration for the Advanced Recovery and Integrated Extraction System (ARIES) equipment in support of the MOX plan (exact numbers are not available to the public). The ARIES equipment has processed as much as 242 kg/yr of plutonium oxide but more recently the rates have been lower (producing 50, 0, and 100 kg in 2015, 2016, and 2017, respectively; see DOE, 2018d, table 7).
CONCLUSION 4-1 (Updated Interim Report CONCLUSION 1): The Department of Energy’s National Nuclear Security Administration’s (DOE-NNSA’s) early-stage plans to dilute and dispose at least 34 metric tons (MT), and as much as 42.2 MT, take advantage of individual process steps that have nearly all been demonstrated by a variety of different DOE programs. As such, the early-stage plans to dilute and dispose provide a technically viable disposition alternative to the mixed oxide (MOX) plan, provided that implementation challenges and system vulnerabilities that currently exist within the plan are resolved.
More concerning is the slow progress to date in processing the 6 MT of non-pit plutonium material, reported in Chapter 3; only about 52 kg (or 0.052 MT) of plutonium oxide has been diluted by DOE’s Office of Environmental Management (DOE-EM) in the Savannah River Site’s (SRS’s) K Interim Surveillance (KIS) glovebox and has not yet been shipped to WIPP. DOE-NNSA has highlighted DOE-EM’s activities to dilute and dispose of 6 MT of surplus non-pit plutonium material as a “proving ground” for its program. However, DOE-EM’s plutonium processing program is in its early stages of development
2 The Master Schedule is available by request through the National Academies’ Public Access Records Office at email@example.com. The Surplus Plutonium Disposition Program Requirements Document for the Dilute and Dispose Approach (DOE-NNSA, 2018) lists the following requirement (p. 15): Requirement P49: Geological Repository Disposal shall provide monitoring capability to support international verification of surplus plutonium disposal.
as well. It now appears that this material will be diluted at the same time and using the same facility as the DOE-NNSA processes as much as 42.2 MT, increasing demand on the facility and resources at SRS.3 Because the 6-MT DOE-EM program is slated to run concurrently with the dilute and dispose program for much of the projected life of the dilute and dispose program, it will not be a particularly robust proving ground for DOE-NNSA’s dilute and dispose program.
3 One significant difference is that a record of decision has been issued for the 6 MT.
In the context of presenting the dilute and dispose plan, DOE-NNSA identified approximately 4.8 MT of plutonium material from Rocky Flats Environmental Technology Site and other sites that had been disposed of at WIPP, some of which was diluted with an adulterant, to show prior capability (McAlhany, 2017). However, the experience gained from processing this earlier material is not completely analogous to the currently proposed dilute and dispose process in that the adulterant, the packaging, and much of the material had different characteristics (Maxted, 2019, and others4). Absent more experience with the dilute and dispose processes as a baseline, there is no reliable set of data to predict the frequency of equipment breakdowns, maintenance, and work stoppages (i.e., unavailability due to planned sharing of equipment and unexpected occurrences).
The committee’s assessments of details of DOE-NNSA’s plan for scaling up operations at Pantex, LANL, and SRS—which are largely manual glovebox operations—can be found in Box 4-1. There was no indication in DOE-NNSA’s planning documents that a technology development plan, for example, to automate glovebox operations, was under development or planned. Further details can be found in Appendix F.
Finally, another committee concern is the development and implementation of a security plan. A security program appropriate to DOE’s assessment of the attractiveness of this diluted plutonium material (see Box 3-2) given the quantity and attractiveness of the source material (e.g., weapons-grade plutonium) requires finalized security and campaign plans. As noted in Chapter 3, parts of DOE-NNSA’s dilute and dispose security plans and their implementation are still under development.
Normally, an extended schedule translates to increased costs. This is true for the dilute and dispose programs, but extended schedules have additional risks: the availability and operational capability of WIPP past 2050 and aging infrastructure at SRS and LANL.
DOE-NNSA estimates completion of the plan to dilute and dispose of 34 MT of surplus plutonium by FY 2049. DOE-EM’s estimated completion date to dilute and dispose of 6 MT is FY 2046 (Maxted, 2019)—a significant overlap of the two programs that was only recently highlighted to the committee. An additional 8.2 MT of surplus plutonium material that could be dispositioned through dilute and dispose methods is not included in these schedules (see Figure 2-1). If there is a decision to disposition these additional materials via dilute and dispose, the timelines would be expected to increase accordingly.
WIPP’s current closure date is 2034, but DOE’s Carlsbad Field Office (DOE-CBFO) plans to request an extension of WIPP’s lifetime to at least 2050 from the New Mexico Environment Department, which manages the permit for WIPP (see Chapter 2). The lifetime extension would conceivably accommodate the emplacement schedule for diluted surplus plutonium transuranic (DSP-TRU) waste as well as TRU waste generated from across the DOE complex.
An independent review of DOE-NNSA’s approach to the LCCE by USACE estimated an end date of at least FY 2056 when contingencies are taken into account; the USACE report states that the dilute and dispose “program finish date does not align with mission requirements” (SRNS, 2018a, fig. 4; USACE, 2018, p. i).5 See Figure 4-2.
Separately, a recent congressionally mandated assessment of pit production options conducted by the Institute for Defense Analyses (IDA, 2019) for DOE-NNSA reviewed DOE’s major projects (those that cost more than $700 million) and found that every one of the projects experienced cost growth and schedule slippage. IDA found no successful major project that achieved CD-4 (CD-4 is Project
4 Information collected during discussions during the open session of the committee’s April 2019 meeting. See video from the meeting available at https://vimeo.com/showcase/6028445/video/338026631 (accessed May 20, 2020).
5 The purpose of the USACE review was to assess compliance of the LCCE approach with “the requirements and best practices of the Government Accounting Office (GAO) for development of capital program cost and schedule estimates, GAO-09-3SP and GAO-16-89G, respectively” (USACE, 2018, p. i).
An extension of the dilute and dispose program timeline, which USACE calculates to be 7 years or more, has serious implications for the availability of WIPP and maintenance of the other infrastructure required. WIPP began operations to accept TRU waste in 1999, but the underground and infrastructure have been in place since 1988. As one example of aging systems at WIPP, during the committee tour of WIPP, the committee was told that the freight elevator was purchased as used equipment when WIPP was originally constructed. The K-Area at SRS, where the round-the-clock dilution, packaging, and storage activities are planned and will be needed for more than two decades, has been assessed by DOE as being in “poor condition” and is 65 years old; at the end of the dilute and dispose campaign, assuming an end date of FY 2049, K-Area will be close to 100 years old. Aging infrastructure in K-Area is acknowledged in the ROAR (SRNS, 2018e, p. 105), which states that the infrastructure has exceeded its design life; infrastructure risks associated with aging included the electrical, fire, exhaust, and chilled water systems and the roof. Similarly, the ARIES facility will be nearly 50 years old. Other infrastructure within DOE sites is, of course, also aging. To highlight the impact of aging infrastructure not specified in the dilute and dispose plans, we cite an example from the risk assessment at SRS from the 2014 Omnibus Risk Review Committee (2015, p. 159):
Several staff noted one particularly serious example of critical infrastructure‐related risks. On January 6, 2014, a polar vortex weather event enveloped the SRS area with unusually cold weather. The … steam and power plant … broke down shutting off steam to site facilities for a week because of a lack of backup steam generation facilities … offsite services that might be counted on normally may not be available and this could compromise safety.
FINDING 4-1 (updated Interim Report Finding 1): The Department of Energy’s National Nuclear Security Administration’s (DOE-NNSA’s) dilute and dispose plan, if implemented, is likely to face several implementation challenges as the program matures (early program development challenges) and over its 30-year lifetime (sustainability challenges). The following are early program development challenges:
- All of the processing steps described in the dilute and dispose plan have not been sequentially demonstrated from start to end, posing a risk since even well-established capabilities run into unforeseen problems when integrated.
- The individual process steps have been demonstrated at prototype levels and the scaling up of current individual operations to a future processing system that can safely and securely generate, transport, and dispose of the diluted surplus plutonium transuranic waste within the desired schedule will be challenging. Some of the process steps such as the glovebox operations lack sufficient operations data to establish baseline throughput values with confidence.
- The initial security assessments and campaign plan have not yet been approved. DOE-NNSA will need to ensure that a security program appropriate to DOE’s assessment of the attractiveness of this diluted plutonium material is in effect and is periodically reassessed and updated, given the quantity and attractiveness of the source material (e.g., weapons-grade plutonium).
The following are sustainability challenges:
- Competition for processing space, human and financial resources, transportation capacity, as well as the Waste Isolation Pilot Plant (WIPP) capacity with other DOE priorities such as DOE’s Office of Environmental Management’s downblending/dilution and disposal plans, pit production activities at the Los Alamos National Laboratory and the Savannah River Site, and transportation of TRU wastes to emplacement in WIPP.
- Maintenance of the infrastructure and expansion of the trained workforce across multiple sites and including transportation that will be required for at least 30 years.
CONCLUSION 4-2: If not addressed, these implementation challenges could lead to extended timelines and increased costs. None of the implementation challenges identified threaten the technical viability of the plan, and many of these challenges could be addressed through improved project plans (as they mature and with independent review), clarified priority for the dilute and dispose program within the Department of Energy, and sufficient, steady funding from Congress. However, such straightforward approaches may not be adequate for some challenges, for example, the ability to hire and qualify sufficient staff, resilience of the nuclear facilities such as the Savannah River Site and the Los Alamos National Laboratory, or the availability of the Waste Isolation Pilot Plant.
FINDING 4-2: The current approach to processing surplus plutonium, from pit size reduction to oxidization to dilution and packaging, relies on many manual glovebox operations (i.e., crushing plutonium oxide pieces that do not pass through a sieve using a mortar and pestle).
Plans to scale up processing to meet the throughput goals for the program rely on duplicating the current processing lines and following the current processing steps. This is a low-risk approach from a technical standpoint but it fails to take advantage of economies of scale and automation. Furthermore, the plan introduces risks associated with aging equipment. The committee saw no evidence of a technology improvement plan.
FINDING 4-3: Plutonium operations are complex and require adherence to many safety and security standards. The dilute and dispose program depends on the long-term availability of adequate nuclear facilities at the Savannah River Site and the Los Alamos National Laboratory and the successful recruiting of a large qualified workforce that can obtain the needed security clearances and be trained and retained to perform the skilled glovebox operations and maintain the stringent safety posture of the facility and equipment over decades.
RECOMMENDATION 4-1: As the dilute and dispose program plans mature, the Department of Energy’s National Nuclear Security Administration (DOE-NNSA) should develop a technology improvement plan that would put more emphasis on seeking newer automated, safer, labor-saving technologies that could avoid human radiation exposure and human error, as well as reduce costs. Once these new technologies are proven safe and technically mature for operational use, DOE-NNSA should be prepared to introduce them into the program.
DOE-NNSA’s dilute and dispose plan relies on existing transportation programs—the Office of Secure Transportation (OST) managed by DOE-NNSA and TRU Waste Transportation managed by DOE-CBFO. Both programs are well established with defined procedures and excellent safety records.
One important aspect of both transportation programs, OST and TRU Waste Transportation, is its coordination with the states. Close coordination and communication along with emergency response training and exercises will need to be conducted and practiced throughout the dilute and dispose duration of at least 30 years and with the expected increased number of transports containing the surplus plutonium material and the DSP-TRU waste.
RECOMMENDATION 4-2: The relationships between the Department of Energy (DOE) and the states’ gubernatorial and operational levels need to be maintained throughout the duration of the multiple dilute and dispose programs in order to support cooperation and to meet the tenets of agreements among state, local, and federal levels of government. Therefore, DOE should maintain communications and its collaborative cooperation with the states through which surplus plutonium material and diluted surplus plutonium transuranic waste will be transported and emplaced.
4.2.2 Risks and Security During Transportation
Nuclear and radiological materials are often considered most vulnerable to theft or loss during transit, as reported by the IAEA and the James Martin Center for Nonproliferation Studies (CNS)6 and other reports (Trimble, 2014; IAEA, 2015). DOE-NNSA and DOE-EM propose to transport up to 48.2 MT of DSP-TRU waste for at least the next 30 years. DOE-NNSA and DOE-EM limit the amount of
6 The CNS report states: “In 2018, 68 incidents (41% of total incidents) occurred during transport, consistent with similarly high rates in previous years…. In many cases, radioactive material theft may have been incidental to the thief’s efforts to steal a vehicle or other valuable equipment. Nonetheless, the occurrence of thefts while material is in transit represents perhaps the most dangerous nexus for incidents in the database” (Meyer et al., 2019, p. 5).
plutonium-239 to a maximum of 300 grams of plutonium-239 per CCO. There are a maximum of 42 CCOs—or 12.4 kilograms of plutonium-239—per shipment (see Chapter 3). This will require up to an additional 3,887 shipments (4.764 million loaded miles) from SRS to WIPP over the projected 30-year life of the dilute and dispose program (assuming 48.2 MT). During steady-state operations, the plan indicates up to four TRU waste shipments per week between SRS and WIPP during the 42-week annual operating window at WIPP from 2024 to 2049.
When this rate is reached and sustained, the levels of risk and concern about theft or diversion increase due to the use of an observable and predictable route, shipment schedule, truck stops for the drivers, and multiple inspection stops. Additionally, more shipments on the road simultaneously provide more targets of opportunity and greater transport security challenges.7
FINDING 4-4: The number of shipments of diluted surplus plutonium transuranic (DSP-TRU) waste from the Savannah River Site to the Waste Isolation Pilot Plant over the proposed schedule will be far greater than for any other TRU waste stream. Additionally, each shipment under the current Department of Energy’s National Nuclear Security Administration’s plans could contain up to 12.4 kilograms of plutonium-239, albeit in diluted form and distributed across 42 criticality control overpacks (i.e., 55-gallon drums).
As discussed in Chapter 3, both OST and TRU waste transportation programs require security plans per Department of Transportation regulation, and both programs have security features in trucks that transport the waste. Although many of the details of the transportation security plans for OST and TRU waste transport are not publicly available, it is known that both the OST and WIPP transportation programs call for redundancy in staffing. WIPP drivers travel in pairs and the loaded vehicle is always under direct observation by one of the drivers.8 The OST shipments are always accompanied by multiple federal agents (Nuclear Materials Couriers) who maintain direct observation as well as ensuring the safety and security of the classified cargo using specialized hardware and equipment.9 Additionally, OST has established mitigating actions to address security risks during transport. As shown in Box 3-4, DOE-CBFO uses TRANSCOM tracking beacons for its TRU waste transport (security tracking capabilities and details are not publicly available for OST). The TRANSCOM tracking beacon is located on the tractor of the TRU waste truck, but neither the trailers nor the individual TRUPACT-IIs currently have satellite tracking beacons.10 As long as the tractor and trailer are connected, authorized TRANSCOM users would be able to approximate the location of the trailers.11 However, should the tractor and trailer become detached, for any reason, the trailer does not have a tracking beacon and could with considerable effort be stolen.
Other mitigating actions to increase security are or have been considered by DOE. For instance, federal escorts were successfully utilized from 1994 to 1995 during the DOE Urgent Cesium-137 Return Campaign from Northglenn, Colorado, to Hanford Reservation, Washington (DOE-EM, 1994, pp. 3, 8).
7 It is worth noting the transportation plan for the MOX option: “Once assembled, each of the fuel assemblies would be transported in SST/SGTs [safe, secure trailer/SafeGuards Transport—a predecessor to OST] to one of the domestic, commercial reactors for use” (DOE, 1999b, p. s-27). The committee was told that the dilute and dispose plan’s campaign plan (see Box 3-2) will assess the risks during TRU waste transport of the DSP-TRU waste from SRS to WIPP. The campaign plan is not publicly available and was not finalized during the committee’s study.
8 For example, see WIPP’s webpage, which states that “Drivers work in pairs to assure that the truck and payload are attended at all times.…” See https://wipp.energy.gov/waste-transportation.asp (accessed March 8, 2020).
10 It is either a common transportation interpretation or an oversimplification of DOE operational procedures that often conveys the concept that “During shipment, the location of each TRUPACT-II is monitored while in transit by using TRANSCOM tracking (tracking is provided for security purposes)” (Haddal et al., 2018, p. 15).
11 TRANSCOM updates every 5 minutes; the transporter is traveling at 60-65 mph and will have traveled along the route before being picked up again by cell tower to satellite.
There is value in securing packages (i.e., TRUPACT-IIs) with electronic tamper indicators, as discussed in Chapter 3, so that DOE-CBFO may independently verify receipt of surplus plutonium TRU waste at point-of-destination. However, electronic tamper indicators do not provide remote tracking capabilities.
RECOMMENDATION 4-3: The Department of Energy’s National Nuclear Security Administration (DOE-NNSA) should periodically update its security assessment for the dilute and disposal campaign given the long duration of the program and the potential that a future operational environment may require different approaches to mitigate potential security risks. The current DOE-NNSA process for such an assessment, utilizing the Materials Risk Review Committee, is viewed as an appropriate approach for such a future assessment that considers both the potential attractiveness of the source material as weapons-grade plutonium and the shipment frequency.
Risk assessment provides a method to identify, understand, and address aspects of an activity that pose the greatest harm (considering both likelihood and consequences). A transportation risk assessment was not specifically conducted within the dilute and dispose plans but is addressed by adherence to multiple regulations and agreements (see Appendix D). For example, the WIPP Transportation Assessment Update in 1998 provides a model transportation risk assessment (ANL, 1998). The 1998 study considered risks to safety; security risks were not considered. Transportation risk also was not assessed in the ROAR. Therefore, the committee is concerned that the existing capabilities and risk assessments have not been adequately considered against the demands that will be encountered by DOE-NNSA’s dilute and dispose plan.
4.2.3 Workforce Development Across the Dilute and Dispose Program
DOE-NNSA’s and DOE-EM’s plans to oxidize surplus plutonium material and dilute the plutonium oxide require the use of gloveboxes, and glovebox operations are largely manual. DOE-NNSA’s plans show significant scaling up of the workforce (a plan from DOE-EM was not available). In addition, the DSP-TRU waste will be transported using commercial transport companies, through contracts with DOE-CBFO.
Many of the jobs require highly specialized workers whose jobs can require significant training time before they become qualified to work. Examples include glovebox work for pit disassembly at Los Alamos, glovebox work for the dilution of plutonium oxide at Savannah River, and the transportation of the diluted plutonium from Savannah River to WIPP. In addition, retention of the skilled workforce will be needed to ensure the success of this program. The programs have additional workforce challenges with the risks of delays at one site (i.e., LANL or WIPP) affecting other sites (i.e., SRS). DOE-NNSA’s plan does have some contingencies for infrequent events, but the committee has concerns about the fidelity of those rates.
The ROAR identifies as moderate risk of causing delays to program execution the need to hire and train staff for SRS operations and limited staffing at LANL (SRNS, 2018d, table 5-3). Workforce attrition and training at Pantex is listed as low risk. As an example, background text for the LANL staffing risk states that “the program is currently (8/2017) experiencing difficulty in adding new staff and is competing with other programs for resources” (SRNS, 2018e, p. 138). Other activities competing for workforce resources are likely to be pit production and other weapons programs that are hiring at higher rates than in the past.
As another example, America’s trucking industry is currently struggling with the inability to acquire trained and experienced drivers who have commercial driver’s licenses, several years of experience with a good safety record over that time with no incidents, and insurance companies willing to insure those drivers. It is forecasted that a shortage of qualified drivers will continue even with the emergence of automated vehicles. Therefore, the need for drivers or operators to monitor vehicles in transit will persist. On July 24, 2019, the American Trucking Association reported that at the end of 2018, America had an
unmet need for 60,800 drivers. If conditions remain the same, they estimate the trucking industry could be short 100,000 drivers in 5 years, and 160,000 drivers in 2028 (Costello and Karickhoff, 2019). In future decades, DOE-CBFO will likely be pressed into innovative hiring practices in order to maintain a workforce of drivers within a competitive environment vying for those drivers.
RECOMMENDATION 4-4: Workforce hiring and retention challenges for the dilute and dispose programs for both the Department of Energy’s (DOE’s) Office of Environmental Management and DOE’s National Nuclear Security Administration will require a focused and sustained effort. The current assessment of risks to the programs may be undervalued. DOE’s Carlsbad Field Office should ensure that it has planned for the future costs of these workforce needs to its transportation system.