Initial Site-Specific De-Inventory Report for Big Rock Point Report No.: RPT-3014537-002
general rule is all clearance submissions are submitted to the Class I carrier, which clears the entire route. Each Class I carrier has a formal procedure for clearance submissions and all are electronically filed. Some require a fee to accompany clearance submissions, some do not. The following components must be present in each clearance submission: 1. Identification of: the origin; the destination; the standard transportation commodity code; the shipper, receiver and associated serving carriers; and the route (including interchange locations for the requested route). 2. Identification of the specific rail car to be used for the shipment. 3. All dimensions of the loaded unit on the rail car, which depict a profile of the loaded unit and car together. These should also include: a. A diagram of offsets, ballasts, or any other loading configuration specifics important to the rail car. b. Center of gravity measurements and total weight of the unit plus the rail car. 4. A diagram of the unit with actual placement on the selected rail car. The more specific the information provided in the clearance submission, the better the chance for clearance acceptance. The above submission requirements are considered a minimum. Some railroads require additional information for clearance acceptance. The AAR Open Top Rules (OTR) delineates what must be submitted for acceptance at interchange between carriers. Note: requirements may be relaxed if movement is restricted to only one railroad and is not subject to interchange with another carrier. This also applies to loading and securement configurations. However, with HAZMAT, the relaxation of these requirements is not expected nor anticipated principally for safety reasons. Furthermore, it is recommended that more than 6 months is allotted for the NRC application process in the event the intended routes have not been approved for previous shipments and the approval process takes longer than anticipated. This recommendation is based on extensive experience in obtaining Superload permits for movements of similar weight and dimensions and HAZMAT (Class 7). Once the rail route is approved by the NRC, it would be valid and effective for 7 years. Combination routes (HHT to rail, rail to HHT) once approved by the NRC are valid and effective for a period of 5 years. The minimum amount of time to submit routes to the NRC for approval is 90 days; however, they would prefer 6 months. 10CFR73 does not identify the length of time an approved barge route is valid; therefore, it is presumed the route is approved only for the length of the campaign. At this time, it is acknowledged that shipments by DOE would not be subject to NRC oversight because DOE would not be an NRC licensee. However, the status of a future Management and Disposal Organization is unknown at this time. DOE policy is to meet or exceed the requirements of the DOT and NRC for comparable commercial shipments, unless national security or another critical interest requires different action. It is assumed in these reports, DOE would follow the same requirements as any other commercial shipper. Once the shipper obtains an approved clearance from the railroads, the clearance is valid for 6 months. The clearance ensures that the submitted dimensions and weights of the load (in this
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Initial Site-Specific De-Inventory Report for Big Rock Point May 10, 2017
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