The Council of State Governments Midwestern Radioactive Materials Transportation Tabletop Workshop – November 13, 2019
Reference Guide
There are distinct regulatory differences between shipments of spent nuclear fuel made (or planned to be made) by the U.S. Department of Energy (DOE) and those made by licensees of the U.S. Nuclear Regulatory Commission (NRC). Similarly, there are distinct differences between shipments by truck, train, and barge. On May 21, 2019, the Nuclear Energy Institute (NEI) hosted a transportation tabletop exercise that helped to shed light on these differences. The exercise helped the states identify the activities they may need to conduct to prepare for shipments by licensees to move spent fuel from shutdown reactors to private storage facilities. The Midwestern Radioactive Materials Transportation Committee (MRMTC) decided to follow up on the NEI exercise with a workshop of its own on November 13 in Indianapolis in conjunction with the Fall 2019 committee meeting. CSG Midwest originally prepared this reference guide for the states that participated in the NEI exercise. The guide has been updated to assist the states and Tribes participating in the MRMTC workshop. The “ shipper ” is the person or company who is usually the supplier or owner of commodities shipped. The “ carrier ” is a person or company that transports goods or people for any person or company and that is responsible for any possible loss of the goods during transport. A “ licensee ” is a company, organization, institution, or other entity to which the NRC or an Agreement State has granted a general license or specific license to construct or operate a nuclear facility, or to receive, possess, use, transfer, or dispose of source material, byproduct material, or special nuclear material. 2. Section 180(c) applies ONLY to shipments to facilities authorized under the Nuclear Waste Policy Act (NWPA) . The only way Section 180(c) would apply to licensee shipments is if the destination were an authorized facility under the NWPA. This is not the case for any storage facilities under development. The states will need to seek alternative sources of funds or technical assistance for licensee shipments because there is no requirement that licensees provide such assistance. The following comparison of licensee and DOE shipments is intended to assist states with their participation in the NEI Tabletop Exercise. It is not an exhaustive list of all the steps required prior or during shipments. The activities are organized roughly in chronological order. Unless otherwise noted, the responsibility for each item is borne by the licensee. It is recommended that all state participants read and bring relevant sections of CSG Midwest’s online briefing book in preparation for the exercise: https://online.flippingbook.com/view/473251/. Important distinctions : 1.
DOE Shipments 1
Item
Authority
Licensee Shipments
Comment
Prior to Shipment Route identification (rail)
DOT-FRA
X
X
49 CFR Part 172.820(c) requires rail carriers to identify annually hazmat routes with input from states (see below) 49 CFR 397.101 (see below)
Route identification (highway)
DOT-FHWA
X
X
1 DOE is not an NRC licensee; however, the department has traditionally committed to “meet or exceed” NRC and DOT requirements for shipments of commercial spent nuclear fuel. Because “meet or exceed” has been DOE’s policy, the table shows that DOE will comply with the same requirements as licensees. It is important to understand, however, that only two provisions are required by the NWPA: the use of certified Type B casks and advance notification of shipments (Section 180(a) and (b), respectively).
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