[T]he parameter thresholds specified in AAR Standard S-2043 could be used to define the thresholds for further train inspections or for stopping a train” (ibid., p. 74). To address confidentiality concerns around sharing inspection reports, DOE proposes a model in which“inspectors under contract to DOE would prepare an inspection report for DOE which could then be shared by DOE with States and Tribes along the transportation route” (ibid., p. 73). In addition to receiving inspection reports from DOE’s contractor, the appropriate state and tribal personnel would be granted access to the data feeds available from the SMS required for S-2043 compliant railcars. The feasibility of using TRANSCOM for the purpose of sharing this data was under evaluation in August 2020. DOE planned to incorporate checklists for the Atlas railcar and buffer railcar Safety Monitoring System in the draft protocol once they were developed (Maheras 2020). DOE’s draft protocol concluded with a list of items to be discussed with the R/R AHWG as the Draft Railcar Inspection Protocol continued to be developed: • Providing AAR Standard S-2043 Data Feeds through the TRANSCOM System: Determining which personnel should have access will likely take place during the development of security protocols for DOE shipments. • Providing a Data Feed Containing Radiation Dose Rate Measurements: While this is not required under S-2043, DOE is considering the feasibility of doing so. • Role of U.S. Nuclear Regulatory Commission: Incorporation of potential transportation-related inspections carried out by the NRC at nuclear power plant sites may be considered by the R/R AHWG. • Out-of-Service Criteria: DOE suggested that the R/R AHWG consider the development of out-of-service criteria under the draft protocol. • Protocol for Further Inspections or Stopping Train: A protocol for stopping a train carrying a DOE SNF shipment and/or conducting additional inspections should be developed taking into account safety and security considerations (Maheras 2020). In its comments, the MRMTC advised DOE-NE to recognize that states and Tribes are unique and that, “in many cases, more than one agency, division, or individual is responsible for the radiological and safety components of railcar inspections” (MRMTC 2020c, p. 1). It would be important, therefore, not to generalize. The states expressed appreciation for the report referring to the proposed inspection process as “a rail analog” to the CVSA Level VI Inspection Program (ibid.). The MRMTC noted, however, that “Level VI is an ‘enhanced’ inspection program,”whereas this “enhanced” quality “does not appear to be the case with the proposed railcar safety inspection protocol” (ibid.). The region encouraged DOE-NE to identify in the revised report “what, if any, inspection elements in the proposed protocol are considered ‘enhanced’” (ibid.). In keeping with its commitment to regional tribal engagement, the Midwest expressed appreciation for DOE-NE including Tribes in
the protocol. The states pointed out, however, that “there are some barriers [to tribal participation] that should be acknowledged” (ibid.). The MRMTC asked DOE-NE to identify the mechanism for Tribes to receive information on inspections — a request that also applies to states that do not participate in the State Rail Safety Participation Program. The Midwest also objected to the report implying “that States expect trains to stop at jurisdictional borders for inspections”— a claim the region described as “frequently made — always without evidence” (ibid., p. 2). The MRMTC concluded its comments with ideas for future work, including an endorsement of the suggestion that the R/R AHWG develop a list of out-of-service criteria and also develop a protocol for conducting en route train inspections and for stopping a train, should it become necessary (ibid., p. 3).
SAFETY COMPLIANCE OVERSIGHT PLAN (SCOP)
The FRA maintains a SCOP, which specifies the steps the FRA or its state-certified inspectors must take in preparation for a shipment or shipping campaign involving SNF or HLW. Addressing concerns around the safety of SNF and HLW shipments is a priority for both DOE and the states. As such, the states were involved in the development of the SCOP in 1998 and are currently providing input on drafts of the revised SCOP.
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