One limitation of Section 180(c) funding is that it is applicable only to spent nuclear fuel and high-level waste shipments to a federal facility authorized under the NWPA. The risks associated with shipments of spent nuclear fuel are similar regardless of the shipper or the destination. As a result, the states believe they should receive financial and technical assistance similar to that intended under Section 180(c) for all shipments of spent nuclear fuel to DOE or private facilities. Another limitation of Section 180(c) funding is that the language in the law specifies funding is to be used for “technical assistance” and “training for public safety officials.”The Midwestern states feel that funding should also be provided for operational expenses. The Midwestern states recognize that operational activities including inspections, escorts, and tracking contribute to safe routine transportation and enhance public acceptance of shipments. Inspections The Midwestern states recognize the value of standardized inspection procedures that can promote reciprocity between state inspections. For truck shipments, the CVSA established its Level VI inspection procedures for shipments of transuranic and HRCQ radioactive material. An equivalent system does not yet exist for rail shipments. However, the DOE is developing a “draft Railcar Safety Inspection Protocol” in conjunction with the NTSF Spent Nuclear Fuel Rail/Routing Ad Hoc Working Group. Point of Origin: Shipments should be inspected by qualified state inspectors prior to departure. A radiological inspection of the package should be part of all point-of-origin inspections. For truck shipments, CVSA Level VI-certified state and federal inspectors will adhere to the CVSA Level VI inspection procedures and other applicable state procedures. The Federal Motor Carrier Safety Administration requires that all vehicles used to transport a highway route-controlled quantity of Class 7 (radioactive) material, defined in 49 CFR part 173 Subpart I,
must have a CVSA Level VI pre-trip point of origin inspection, as defined in 49 CFR 385.415. Vehicles may not be released from their point of origin until they are defect free of all Level VI inspection criteria. For rail shipments, motive power and equipment and hazardous material inspections will be conducted in accordance with federal regulations and state requirements, and should be conducted in accordance with the 2023 FRA SCCOP, Association of American Railroads recommended practices, and industry standards. All inspections of equipment and packages should be performed either by, or in the presence of, an FRA-certified state inspector or if a state does not have a certified state inspector, a federal inspector. Rail shipments should not be dispatched until they comply with the aforementioned standards and recommended practices. En Route: At their discretion, states on the shipping routes may choose to inspect shipments and they reserve the right to choose the level of inspection to conduct. To encourage reciprocity, shippers of large-scale campaigns should coordinate with states to develop an approach to inspections that recognizes state laws, policies, or rules that require inspections. The inspection points should be determined well in advance of the shipment. For truck shipments, ports of entry are generally acceptable. For rail shipments, the shipper and carrier should strive to arrange crew changes, routine inspections, etc., at a point that will accommodate the needs of state inspectors. To meet the intent of state policies or laws, the inspection points for rail and truck shipments should be reasonably close to the state’s border. One Midwestern state (Illinois) requires en route inspections of all shipments of spent nuclear fuel, high-level radioactive waste, transuranic waste, and HRCQ shipments of radioactive material. Other states may choose to conduct en route inspections at their discretion. Shipments by truck must not proceed until any out- of-service criteria violations have been corrected consistent with federal regulations and CVSA Level VI criteria. Rail shipments
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