Initial Site-Specific De-Inventory Report for Big Rock Point Report No.: RPT-3014537-002
3) The Third Closest Rail siding to BRP – Gaylord, MI, on LSRC Rail siding is located 52 miles from site. It is a better rail route for extreme dimensions and very heavy loads (heavier than the SNF cask cars). The truck route to Gaylord is through Petoskey and has been permitted for past shipments in October 2003. This Class II carrier (LSRC) has one direct interchange with Class I CSX in Flint, MI. It has direct connections with two other Class II carriers: (1) HESR in Bay City, MI and Saginaw; and (2) MMRR at Paines, MI. The recommended route for this loading location is LSRC to Flint, MI for direct interchange with Class I, CSX. There is only one carrier in the route before interchange with Class I carrier. There is no advantage to involving HESR in the route because it only connects with CSX and there is a more direct route from LSRC to CSX via the Flint, MI interchange (LSRC- Flint-CSX), limiting the number of carriers in the route to one, before interchange with a Class I railroad. 3.2.2 BRP – Canister Transloading On or about 2006, many Class I carriers began to prohibit transloading certain commodities on railroad property, even if the shipper leased the property from the railroad. This is an unwritten “policy” based on risk assessment by many of the Class I carriers. This is not a recommendation from any authoritative body like the AAR. It began when leased railroad property was being returned contaminated, resulting in the sites being deemed Superfund sites with the carriers having to pay to restore the sites to brownfield status. These clean-ups became very expensive. As a result, many of the railroads instituted a policy whereby certain commodities will not be allowed to be transloaded on railroad property, even through a land or track lease. The AAR and CHEMTREC do not have jurisdiction over what a railroad decides to do with its property and track, as long as the commodity is legal to transport. To date this policy has been enforced with various radioactive and hazardous materials (HAZMAT). This policy has applied to all HAZMAT including Class 7 LLW and commodities like Toxic Inhalation Hazards (TIH) and Poisonous Inhalation Hazards (PIH). For example, a shipment of Class 7 LLW components from West Valley, NY could not be transloaded on Class I carrier property because of this “policy”. It further extends to railroad-owned transfer sites (i.e., rail transload facilities owned and operated by many of the Class I carriers that transload various hazardous commodities on behalf of shippers). HAZMAT classes 1, 2.3, 4, and 7 are not transferred in these facilities or on most other railroad owned property. The rail transload facilities view sulfuric acid as the most hazardous commodity they will transfer today because of the employee risk, cleanup requirements, insurance costs, and environmental impact. Based on recent interactions with several Class I carriers, it is presumed this policy will continue to be observed. However, if the DOE Settlement Agreements with the Class I carriers allows for future SNF transloads on railroad properties, then the outcome of this assessment may change.
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Initial Site-Specific De-Inventory Report for Big Rock Point May 10, 2017
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