The CVSA Level VI program involves a comprehensive point-of- origin radiological and vehicle inspection that takes place once the truck has been fully loaded. Conducted by qualified law enforcement officers, the inspections are a regulatory requirement. The Level VI program is built on reciprocity, meaning that most states do not require a vehicle that has undergone a Level VI inspection to be inspected upon entering the state. In cases where a state does require a shipment to be inspected upon entering its borders, it is frequently a less detailed inspection. On the rail side, there are numerous regulatory requirements for railcar safety inspections and hazmat inspections. These inspections are conducted by rail carriers with oversight/ auditing from FRA inspectors or FRA-certified state inspectors. Unfortunately, not all states have the means to participate in the FRA’s State Rail Safety Program. Even those who do participate cannot all maintain inspectors in every discipline. A significant deficit of the rail inspection system is that there is no mechanism sharing rail safety inspection reports from a point of origin inspection or en route inspections. Because of these limitations, the states would like to see an equally stringent, transparent, and universal inspection program for rail shipments to promote reciprocity and, thereby, facilitate the transport of SNF by rail. There are three key benefits of a reciprocal rail inspection program: 1. The program would consist of uniform standards and training for carrying out inspections. 2. The format for documenting the results of an inspection would be standardized. 3. The inspection reports under a reciprocal program would be communicated to “downstream” states and organizations (Edwards and Runyon 2009). Working through the TEC/WG Rail Topic Group, DOE and its stakeholders developed a reciprocal rail inspection protocol based on U.S. DOT requirements. In 2010, two years after DOE disbanded the TEC/WG, the Midwest, Northeast, and the FRA completed their effort to advance the work previously started by the Rail Topic Group. The 2010 inspection protocol included forms for documenting the results of both locomotive and railcar inspections (CSG Midwest et al. 2010). In 2015, when DOE-NE established the R/R AHWG, the two priorities the group identified were the development of a reciprocal rail inspection protocol and route selection (R/R AHWG 2015a). The AHWG picked up the work that the Midwest, Northeast, and the FRA had done five years earlier, adding in the new S-2043 standards and steps to the design of DOE’s Atlas railcar. Specifications for the S-2043 railcar require that several characteristics be monitored continuously, including location, speed, bearing condition, and braking performance (Maheras 2019a). There was also an open question of whether DOE would impose more stringent standards
for its rail shipments of SNF and HLW than those imposed by the AAR 8 . While DOE itself does not have the authority to regulate rail shipments, a reciprocal rail inspection protocol could ultimately be embedded in FRA regulations, similar to the CVSA Level VI inspection for trucks, or added into directives for shipments or contracts for services under a DOE transportation program. Reciprocal rail inspections were discussed at the May and November 2015 meetings of the R/R AHWG. A presentation by the FRA explained the vision for a process under which a comprehensive point-of-origin inspection would be performed, and the results would be made available on a DOE website to be viewed by states and Tribes along the route. States could then perform comprehensive or limited en route inspections, the results of which would also be available online to authorized personnel. Prior to doing a state inspection, the inspector would review the results of the point-of-origin inspection and previous state inspections. From an operational perspective, the FRA would prefer to see state inspections occur during refueling, crew changes, or when the train is otherwise already stopped. When a shipment reaches its final destination, another comprehensive inspection would occur and be documented.
8 AAR Standard S-2043 is more stringent than the regulatory requirements imposed by the FRA. DOE may elect to set higher standards for its shipments of SNF and HLW; these higher standards would need to be agreed to by the railroads and specified in the contract between DOE and the shipping railroad.
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