Initial Site-Specific De-Inventory Report for Big Rock Point Report No.: RPT-3014537-002
8.0 SAFETY AND SECURITY PLAN AND PROCEDURES The purpose of the Safety and Security Plan is to provide an overview of the direction and control for the safe and secure transportation of HAZMAT. The Safety and Security Plan encompasses strategies and procedures in compliance with 49 CFR 172.800-822. It ensures the safety of the material, employees, and the public during loading, truck transportation, transloading activities, barging, and rail movement associated with the transportation of the SNF and GTCC LLW from the BRP site to the final destination and the security of this shipment. The transportation activities covered by the plan include the shipment, by on-site HHT, of the casks from the BRP ISFSI site to the secure rail siding transload facility which is located on a Class II regional railroad along Clarion Avenue in Petoskey, MI, and movement on rail from the Class II to the Class I carrier (in Durand, MI) for final delivery to the hypothetical destination of the GCUS. The basic statute regulating HAZMAT transportation in the U.S. is 49 U.S.C. 5101 et seq. Section 5101 identifies “hazardous materials” by commodity or a group of commodities. It identifies regulations for the safe movement of HAZMAT, including safety and security for movements within the U.S. The entities with jurisdiction over commercial transport of SNF in the U.S. include: the NRC and the DOT. The DOT’s PHSMA issues the Hazardous Materials Regulations (HMR) in 49 CFR 171-180 and represents the DOT in international organizations. Another organization that will be involved in the transportation of overpacks from the BRP ISFSI site is the USCG. The relevant regulations addressing the security of SNF during transportation include: 49 CFR 172-177; 10 CFR 73.20, 73.37 and 73.72; and 49 CFR Subpart I. Several agencies have jurisdiction over different aspects of commercial transportation of HAZMAT depending on the mode of transport and other circumstances of the shipment. These agencies include: PHMSA, Federal Motor Carrier Safety Administration (FMCSA), FRA, Federal Aviation Administration (FAA), and USCG. Together these entities cover all aspects of commercial transportation of a hazardous material, which includes the movement of SNF, by road, rail, air, or water with an emphasis on safely moving this material. The aforementioned MTSA plan will govern the water-served site, even though the recommended mode of transportation is by HHT to a transload to rail site in Petoskey, MI. Any site whether private or public that is on or adjacent to water will be governed by the USCG regulations and MTSA provisions will apply to the site. The local Captain of the Port (COTP) may designate the area a Safety Zone during loading operations as a means of providing an additional layer of security to the site. As an MTSA-designated site, the USCG will have authority over reviewing and approving the Safety and Security Plan. While maintaining security protocols relevant to the control of sensitive information regarding the movement of the SNF and its associated procedures, all relevant parties to the transportation activity will receive a copy of the Safety and Security Plan, supplemented by training to its contents. All personnel will be required to return a signed copy of the Safety and Security Plan review signature sheet to the designate site administrator as part of documentation control.
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Initial Site-Specific De-Inventory Report for Big Rock Point May 10, 2017
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