MRMTC Tabletop Workshop Reference Documents

The licensee also shall coordinate shipment schedules and itineraries with the receiver at the final delivery point to ensure that the receiver is present to accept the shipment. Additionally, if applicable, any transfer of custody (in which armed escorts transfer responsibility for the shipment) during the shipment must be preplanned and coordinated to ensure that the required written certification of the transfer of custody is properly documented and completed. The licensee is also required to protect SGI in accordance with 10 CFR 73.21 and 10 CFR 73.22. Preplanning and coordination activities should address how this information will be protected, especially the determination of the trustworthiness and reliability of any individual whose assigned duties will provide access to the SNF shipment information. The licensee should document the preplanning and coordination activities and protect sensitive information as SGI as specified in 10 CFR 73.21 and 10 CFR 73.22. The types of activities that should be documented include, but are not limited, to timelines for outreach to States (e.g., meetings, teleconferences), summaries of planning meeting discussions, and lists of personnel contacted. Although not a requirement, a best practice also would be to preplan and coordinate shipment details no later than 2 weeks before the shipment or before the first shipment of a series of shipments with the Tribal official, or the Tribal official’s designee of each participating Tribe’s reservation through which or across whose boundaries the shipment will pass. 2.2.1. Avoidance of Intermediate Stops To satisfy 10 CFR 73.37(b)(1)(iv)(A), the licensee should ensure that intermediate stops and delays are kept to a minimum. Intermediate stops should be avoided to the extent practicable because it is recognized that a shipment is generally more vulnerable to attempts at theft, diversion, or radiological sabotage when stationary. Scheduled stops for SNF shipments should be justified by a security or operational need for making the stop. When possible, stops should be planned to serve multiple purposes and to avoid set patterns in the times and places they occur. 2.2.2. Procedures at Stops Shipments are vulnerable to attack while stationary. In accordance with 10 CFR 73.37(b)(3)(vii)(C), the licensee shall ensure that at least one armed escort other than the driver maintains constant visual surveillance of the shipment and reports to the movement control center at regular, pre-set intervals not to exceed 30 minutes during periods when the shipment vehicle is stopped or the shipment vessel is docked. Maintaining surveillance of the shipment during these periods is intended to ensure that any attack would be detected as early as possible so that the adversary would have only a minimal amount of time to attempt theft, diversion, or sabotage of the SNF before response forces arrive. 2.2.2.1. Stops during Road Shipments The licensee should ensure that, when a shipment has stopped, the armed escorts maintain visual observation of the transport vehicle to detect tampering with or unauthorized access to the shipment. The visual observation by the armed escorts should include periodic walks around the vehicle. Multiple armed escorts should be separated to prevent being simultaneously incapacitated by a single adversary act. Additionally, 10 CFR 73.37(c)(2) requires, as permitted by law, that each armed escort be equipped with a minimum of two

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