ML19163A286
| ML19163A286 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/2019 |
| From: | Jane Chimood NRC/OIP |
| To: | NRC/OIP |
| Chimood J | |
| Shared Package | |
| ML19160A001 | List: |
| References | |
| Download: ML19163A286 (3) | |
Text
From: Chimood, Jane To: OIP_Notifications Resource
Subject:
FW: RE: RE: Self-Disclosed notification violation of import regulations in 10 CFR 110.50(c)(3)(ii)
Date: Wednesday, June 12, 2019 2:51:36 PM Attachments: US Import Requirements.docx From: Elrod, Jim K <james.elrod@bhge.com>
Sent: Wednesday, May 15, 2019 8:29 AM To: Baker, Stephen <Stephen.Baker@nrc.gov>
Cc: Chimood, Jane <Jane.Chimood@nrc.gov>
Subject:
[External_Sender] RE: RE: Self-Disclosed notification violation of import regulations in 10 CFR 110.50(c)(3)(ii)
- Stephen, I appreciate your input and will work toward the same goal. I did make further adjustments to the US import requirements document as suggested. ( good catch on the date thing. I should have caught that)
I personally, and as the representative for Baker Hughes, want to always do my best with handling this type issue and always appreciate your input. The attached latest revision refers direct to the notification required for Cat 2 or above imports.
If I have not used the correct official name for your agency please let me know and I will make the adjustment. Sometimes agency names are so long I could have made an error.
I hope we can avoid further escalation of this. I know Customs and other organizations dont like surprises and the notifications required for Category 1 or 2 shipments being imported or exported should be adhered to.
Last but not least, I apologize if some of my responses have not been at the appropriate level of diplomacy. No excuse is acceptable, but I personally have had a difficult start to the new year. I will strive to make the attitude adjustments necessary so I can get back to my normal and better view on things. I have worked with you so much over the years, it has been a pleasant experience.
Any other suggestions on adjustments needed on our process would be appreciated.
Jim Elrod Radiation Safety Officer/Coord/Supervisor II Baker Hughes GE Products & Technology Baker Hughes, a GE Company T + 1 713 879 3627 l M + 1 713 205 3031
PRE-ALERT REQUIREMENTS FOR ALL SHIPMENTS TO THE U.S. INCLUDING DATA REQUIRED FOR IMPORTER SECURITY FILING (Rev. May 2019)
- Notify Party: Add this information to the Notify Party block on all air way bills and ocean bills of lading inbound to the US (excludes courier shipments):
Expeditors International 18255 Humble Parkway Humble, TX 77338 281-913-2800 Attention: Baker Hughes Account Rep
- Pre-Alerts: Pre-alerts including scanned documentation identified in the U.S. Standard Shipping Instructions MUST be sent for every shipment consigned to Baker Hughes Product Lines anywhere in the U.S. to the e-mail addresses below according to mode of transportation:
All Ocean and Air Shipments onelogisticsusaimportop@bakerhughes.com and iah-baker.hughes@expeditors.com Truck Shipments from Mexico - same as above All Truck Shipments from Canada:
onelogisticsusaimportop@bakerhughes.com and borderprealerts@expeditors.com All Courier Shipments (only use FedEx or DHL Express):
onelogisticsusaimportop@bakerhughes.com And either DHL Express: bakerhughescvgteam@dhl.com or FedEx: BUFCPAMAIN_B@ftn.fedex.com; and kenneth_martin@ftn.fedex.com
- Pre-alert Subject Line Format:
Pre-alert subject line to include transport mode, SAP Shipment Number or Invoice Number, and other relevant data needed. Radioactive shipments subject line must begin with word Radioactive. Courier subject line must start with BK to identify Baker shipment and include the air bill tracking number:
Examples for Subject Line (vendors use PO# instead of Shipment#)
Air, Shipment #1528114 Ocean, Shipment #1528114 Truck, Shipment #1528114 Prealert: BK Courier, Shipment #1528888, air bill tracking no.
Radioactive, Shipment #1528888 Page 1 of 2
The requirements below in red are for radioactive shipments only.
- MANDATORY: 10 day prior to shipment notification must be sent to Jim Elrod or Rick Rice for determination on whether a US NRC notification is required prior to shipment.
If applicable notification will be sent to US NRC Office of International Programs at the following email address: hoo.hoc@nrc.gov Approval to ship will then be given to exporting location.
- A copy of their approval must be included with Green Light Approval request and pre-alert.
- Pre- alert must contain Flight Number, ETD origin, and ETA destination.
- Radioactive sources include RADIOACTIVE in email subject line
- In addition to above distribution, copy Jim Elrod: james.elrod@bakerhughes.com and Ricky Rice :
ricky.rice@bakerhughes.com OCEAN Freight/ ISF (10+2) Requirements -
Potential penalty for failure to comply:
To be compliant with US Customs regulations for ISF the following must be emailed to the same pre-alert contacts preferably 72 hos (minimum 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) prior to departing from origin.
Pre-alert must contain the below:
- House B/L and/or Master B/L
- Commercial Invoice
- Packing list
- Mill Certificates if required. (stated in the US Shipping requirements)
- ISF form with full detils completed ALERT: U.S. CUSTOMS IS ENFORCING TIMELY IMPORTER SECURITY FILING BY IMPOSING PENALTIES. PENALTIES IMPOSED DUE TO SHIPPING LOCATION NOT ADHEREING TO THESE REQUIREMENTS WILL BE RESPONSIBLE FOR THE PENALTIES INCURRED.
U.S. IMPORT OPERATIONS & C-TPAT NAME TITLE OFFICE PHONE E-MAIL Laura Arrambide Logistics Analyst - U.S Imports 713 879-2140 laura.arrambide@bakerhughes.com Ruby Medrano Logistics Analyst - U.S. Imports 713 879-2157 ruby.medrano@bakerhughes.com Ryan Frazier Logistics Analyst - U.S. Imports 713 879-2726 ryan.frazier@bakerhughes.com Julie Obecanov C-TPAT Logistics Manager 713-879-2197 julie.obecanov@bakerhughes.com Zettie Eversole U.S. Import Manager 713 879-2136 zettie.eversole@bakerhughes.com
- expo: Shippers wanting to obtain an Expeditors expo account for visibility to BH shipment status and documentation via the web using BH reference #s. To secure an account, use the Register feature at:
http://expox.expeditors.com/expo/Login.jsp?status=default&browserVersion=ie4up.
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