of the immobilization or to significantly shorten the time needed to make the transport operational again. • The device should pose no significant safety hazard before, during, or after the immobilization. 3.3.2. Immobilization Device Design Devices employed to effect immobilization may be mechanical or electrical. They should be relatively simple and reliable to operate, so that they can be activated quickly under stressful conditions. The following are some techniques that may form the basis for acceptable immobilization procedures: • severing the main wire harness under the dashboard • disabling a critical portion of the ignition system by overloading or dismantling a key component of the ignition system or starting system • disabling the gear shifting mechanism • using an electronic ignition control system with a procedurally irreversible time delay feature 3.3.3. Format of Approval Request The licensee shall submit a letter to the NRC requesting approval of the intended immobilization device in advance. The device specification shall be attached to the letter and protected in accordance with 10 CFR 73.21 and 10 CFR 73.22. 3.4. Training Program for Drivers Transport vehicle drivers are required in 10 CFR 73.37(c)(5) to be familiar with and capable of implementing transport vehicle immobilization, communications, and other security procedures. The extent to which drivers may become involved in the physical protection of the shipment depends on the arrangements made between the carrier and the shipper or receiver (licensee). The greatest degree of driver involvement would occur when the driver is also a fully trained armed escort and alternately assumes driving and physical protection responsibilities with other armed escorts. However, in other circumstances, the driver may have only minimal responsibilities in protecting the shipment. In all cases, as required by Section 73.37(c)(5), the licensee must ensure that the driver is familiar with the basic security functions of transport vehicle immobilization, redundant communications systems, and any other security procedures that would affect the driver’s operation of the transport vehicle. The licensee should review the roles and responsibilities of the driver and ensure that the required training is conducted before the SNF shipment commences.
24
Made with FlippingBook - Online Brochure Maker