Safety and Security CARRIER/DRIVER REQUIREMENTS The states have advocated for OCRWM to adopt requirements for high-quality carriers and drivers, including train crews, that are at least as stringent as those for truck shipments of transuranic waste to WIPP. Parallel requirements have not been established for rail shipments, although the states’ position is that these should be comparable to the standards for truck shipments. DOE describes the minimum carrier and driver requirements to which it will adhere in the DOE Manual. OCRWM describes additional carrier and driver requirements that will apply to spent fuel and high-level waste shipments in its Draft Request for Proposals (RFP) for transportation services for moving commercial spent fuel to the federal repository. OCRWM will need to augment its proposed standards if it is to meet the states’ expectations. DOT establishes regulations that apply to commercial carriers, such as training for drivers that transport highway route controlled quantities (HRQC) of radioactive material, including spent fuel and high-level waste. These regulations require that drivers transporting HRCQ shipments receive written training on the specific DOT requirements pertaining to such shipments; the properties and hazards of the materials being shipped; and the procedures to be followed in the event of an accident or other emergency (DOE 1986c, p. A-98). Drivers must have received training within two years prior to transporting radioactive materials, and they must carry their certificate of training with them. In September 1998, OCRWM issued a revised draft Request for Proposals (RFP) for transportation services for moving commercial spent fuel to the federal repository. The RFP laid out requirements for several areas of transportation, including carrier and driver qualifications. The RFP stated that carriers must develop training programs for truck drivers and locomotive engineers that comply with DOT’s 49 CFR. In addition to the training required by 49 CFR, driver and crew training should also cover, as appropriate (DOE 1998a, p. 8-6): • operation of the specific package tie-down systems • cask recovery procedures • use of radiation detection instruments • use of TRANSCOM and other communications equipment
Carrier and driver requirements are one of the 14 topics covered in the DOE Manual, which cites the same requirements in the 1998 RFP. While carriers bear the ultimate responsibility for following the relevant federal regulations for transporting radioactive materials, DOE monitors carrier performance and ensures that each driver possesses “a current commercial driver’s license (CDL) with a hazardous material endorsement and meet[s] applicable requirements in 49 CFR” (DOE 2008f, p. 25). Rail carriers must also follow the applicable regulations in 49 CFR. The FRA sets minimum standards for driver and crew training, but additional training is frequently provided by carriers in accordance with industry standards. The DOE Manual commits to having DOE shipments meet standards and recommended practices set by the Association of American Railroads. The FRA mandates that workers receive job-specific training at least every three years. FRA regulations also require engineers and crews to undergo drug and alcohol screening. According to the DOE Manual, “Regulatory conformity on the part of rail carriers in the area of rail safety (including crew training and preparedness and equipment inspection) is assured by rail industry rules, standards, and recommended practices which correspond with and in some cases enhance said regulations” (ibid., p. 26). Thus, DOE relies on the rail industry to be largely self-regulating in the area of rail safety. The states will likely seek additional assurances that rail crews and locomotive engineers are properly trained and qualified to conduct shipments. The states have advocated for OCRWM to adopt requirements for carriers, drivers, and train crews for repository shipments that are at least as stringent as those for WIPP drivers. TheWIPP PIG, developed jointly by theWGAWIPP Technical Advisory Group and DOE, describes the “issues, objectives, approaches and procedures” that govern highway shipments of transuranic waste through theWestern states (WGA 2008c, p. i). “High–Quality Drivers and Carrier Compliance” is the very first transportation issue addressed
• adverse weather and safe parking procedures • public affairs and speakers bureau training • first responder awareness training • radiation worker “B” (or equivalent) training
Truck drivers must also receive training in CVSA’s enhanced inspection procedures. Rail crews must receive training in hazardous material handling in compliance with individual railroad operating rules.
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