Information Notice 1992-72, Employee Training and Shipper Registration Requirements for Transporting Radioactive Materials

Employee Training and Shipper Registration Requirements for Transporting Radioactive Materials

ML031200366
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date:	10/28/1992
From:	Burnett R NRC/NMSS/IMNS
To:
References
IN-92-072, NUDOCS 9210220115
Download: ML031200366 (4)

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C.

20555

October 28, 1992

NRC INFORMATION NOTICE NO. 92-72:

EMPLOYEE TRAINING AND SHIPPER

REQUIREMENTS FOR TRANSPORTING

MATERIALS

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REG I STRAT ION

RADIOACTIVE

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Addressees

All U.S. Nuclear Regulatory Commission licensees.

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Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice to review two recent rulemaking actions completed by the U.S.

Department of Transportation (DOT).

These recently effective regulations

prescribe requirements for training employees who perform any function subject

to the requirements of DOT Hazardous Material-Regulations, and establish DOT

registration and fee requirements applicable to any person who offers for

transport specified quantities of radioactive materials.

This notice applies to licensees who prepare and deliver radioactive material

packages to common or contract carriers,- or who prepare and transport packages

as private carriers. It is expected that licensees will review the DOT

requirements for applicability to their licensed activities and consider

actions, as appropriate, to ensure compliance when shipping packages

containing radioactive materials. However,; suggestions contained in this

notice do not constitute any new NRC requirements, and no written response is

required.

Background

NRC and DOT share primary responsibility for regulating the transportation of

radioactive materials within the United States. -NRC-regulations for the

transportation of radioactive materials are codified in 10 CFR Part .71,

"Packaging and Transportation of Radioactive Materials."

DOT's hazardous

materials regulations, which address radioactive materials, are codified in

49 CFR Parts 100-199.

A provision in the NRC regulations, 10 CFR 71.5, requires that NRC licensees comply with DOT's hazardous material regulations.

Discussion

The first DOT

Materials, 57

'Subpart H --

rulemaking action (Training for Safe Transportation of Hazardous

FR 20944, May 15, 1992, excerpted amendments attached) adds

Training" to 49 CFR Part 172, "Hazardous Materials Tables

9210220115 k~A-l

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IN 92-72 October 28, 1992 and Hazardous Materials Communications Regulations." The second action

(Hazardous Materials Transportation; Registration and Fee Assessment Program,

57 FR 30620, July 9, 1992, excerpted amendments attached) adds "Subpart G --

Registration of Persons Who Offer or Transport Hazardous Materials" to

49 CFR Part 107, "Hazardous Material Program Procedures."

The following

discussion summarizes major requirements included in the two actions;

licensees are advised that the Subparts contain additional requirements that

may be applicable to their programs.

(1) Hazardous Material Employee Training

(49 CFR Part 172, Subpart H, Sections 172.700-172.704, effective

July 1, 1992)

The training is described in 49 CFR 172.700(b) as a systematic program that

ensures a hazmat employee has familiarity with the general provisions of the

hazardous material regulations (49 CFR Parts 171-180), is able to recognize

and identify hazardous materials, has knowledge of specific requirements of

the hazardous material regulations applicable to functions performed by the

employee, and has knowledge of emergency response information, self-protection

measures and accident prevention methods and procedures.

Section 172.702 requires that hazmat employers ensure that hazmat employees

are trained and tested on the training subjects covered in Section 172.704.

Paragraph 172.704(a) contains more specific requirements for general

awareness, function-specific and safety training.

Subparagraph 172.704(a)(2)

requires that hazmat employees receive training concerning hazardous material

regulatory requirements specifically applicable to the functions the employee

performs.

For example, 49 CFR 177.842(d) requires that packages be so blocked

and braced that they cannot change position during conditions normally

incident to transportation. Subparagraph 172.704(a)(2) requires that an

employee performing blocking and bracing be trained to perform that function.

Paragraph 172.704(c) requires that initial training for each hazmat employee

employed before November 15, 1992, be completed prior to April 1, 1993, and

that training for hazmat employees employed after November 15, 1992, be

completed within 90 days after employment.

The paragraph also requires that

hazmat employees receive required training at least once every two years.

Paragraph 172.704(d) contains training recordkeeping requirements.

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IN 92-72 October 28, 1992 Hazmat employee training requirements are also contained in 49 CFR Part 177,

"Carriage by Public Highway" (also effective July 1, 1992).

Paragraph

177.800(c) prohibits private, common, or contract carriers from transporting a

hazardous material by motor vehicle unless each of its hazmat employees

involved in that transportation is trained as required by 49 CFR 172 Subpart H.

(2) Hazardous Material Shipper/Carrier Registration

(49 CFR Part 107,-Subpart G, Sections 107.601-107.620, effective

August 31, 1992)

As described in Section 107.601, the registration and fee requirements of

Subpart G apply to any person who offers for transportation, or transports, in

foreign, interstate or intrastate commerce, any highway route-controlled

quantity of radioactive material.

(A highway route-controlled quantity is

defined as a quantity within a single package which exceeds 3,000 times the

appropriate A value as specified in 49 CFR 173.433 or 30,000 curies, whichever

is least).

The requirements also apply to a shipment of 5,000 pounds gross

weight or more of a class of hazardous material(s) for which placarding is

required.

Section 107.606 contains exceptions from the Subpart for Federal, State, and

3cal agencies, and other persons.

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Section 107.608 contains the general registration requirements, including a

provision that no person required to file a registration statement may

transport or cause to be transported or shipped hazardous materials, unless

such person has on file, in accordance with Section 107.620, a current annual

DOT Certificate of Registration.

Section 107.616 contains payment procedures for the annual fee, established at

$300 in Section 107.612.

Section 107.616 also describes an expedited

registration process ($350).

Section 107.620 describes recordkeeping requirements, including a requirement

for each person to maintain copies of the registration statement, payment

instrument, and Certificate of Registration for a period of three years from

the date of issuance of each Certificate of Registration. This section also

requires each motor carrier to carry a copy of its Certificate of Registration

on board all transport vehicles used to transport hazardous materials.

Licensees are reminded that compliance with DOT regulations is subject to NRC

and DOT inspection, and that licensees are responsible for maintaining

awareness of applicable DOT regulatory requirements.

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IN 92-72 October 28, 1992 This information notice requires no specific action or written response.

If

you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate regional office.

Questions about DOT requirements should be directed to DOT.

M RobAt F. Burpett, Director/

Di 'sion of !feguards and Transportation

Office of Nuclear Material Safety

and Safeguards

Technical contacts:

John R. Cook, NMSS

(301) 504-2458

George Brown, DOT

(202) 366-4545 Attachments: 5 ¢ FdA TO/Q4H-t

1. Copy of amendments from DOT Final Rule on hazardous

material employee training (57 FR 20952)

2. Copy of amendments from DOT Final Rule on hazardous

material shipper/carrier registration (57 FR 30630)

3. List of Recently Issued NMSS Information Notices

4.

List of Recently Issued NRC Information Notices