Initial Site-Specific De-Inventory Report for Big Rock Point Report No.: RPT-3014537-002
Based on the experience of the authors in conducting transfer operations of HAZMAT, including Class 7 commodities, Class II and III railroads are open to allowing these hazardous commodities to be transloaded on railroad properties, provided the shipper enters into track and lease agreements with the railroad. A track lease is a legal agreement between the owner of the land and track (railroad or private property owner) and a shipper or transloader that wants to use that property and track. For a longer-term operation, the shipper/transload facility will pay a monthly fee to use the land and track for a specified time. Therefore, it is likely that transloading SNF and GTCC waste would be allowed on a Class II property with a lease. There is a precedent for transloading radioactive materials on leased Class II property. For example, in 2014 and 2016 MHF Services could gain approval to load Class 7 LLW on Buffalo and Pacific Railroad (BPRR) property in New York and on the Terminal Railroad Association (TRRA) property in East St. Louis. Both movements required setting up temporary transload operations to load three components from truck to rail. Experienced shippers conducting transloads, especially for dimensional and hazardous cargo on Class I and Class II railroads and on private tracks, have had lower costs with private tracks and Class II carriers than on Class I carriers. In a recent loading in June 2015, $25,000 was charged for use of a Class I railroad siding (700' of track) in a rural part of western Pennsylvania for loading dimensional cargo on three load cars flanked by buffer cars. The closest Class II was not going to charge for its loading track. In addition to charging practices for Class II carriers, experience transloading Class 7 LLW components in New York resulted in CSX railroad (Class I carrier) refusing to allow the transfer on its property, whereas BPRR agreed and charged nothing for using a loading track within its active rail yard. Based on experience, certain terms and conditions may have to be accepted, including but not limited to, conducting direct transfers from the truck to the rail car without the casks being placed on the ground and inclusion of indemnification clauses in the track leases as a condition of leasing the properties. Because of this policy, the recommendation is to truck the casks from the BRP site to a secure rail transload facility where the casks will be loaded onto rail cars for movement via dedicated train from the Class II railroad, that will interchange the loaded cask train with the nearby viable Class I carrier. Unless a suitable existing transload facility with enough track to support the operation is in the target area, DOE or a subcontractor/designee would have to establish one. This can be accomplished fairly easily and economically and there are distinct advantages to the shipper to A physical site survey must take place to determine the best available rail-served properties that can be obtained (leased) and secured for setting up the transload facility. Any location used for rail transloading operations will need to comply with 10CFR Part 73.c and d, Physical Protection of Plants and Materials [21] , Special Physical Protection of Special Nuclear Material in Transit. This will include evaluation of several factors including but not limited to the following: establishing and running a private rail transload facility. Considerations for selecting a rail transload facility:
Page 3-12
Initial Site-Specific De-Inventory Report for Big Rock Point May 10, 2017
Made with FlippingBook - Online Brochure Maker