in theWIPP PIG. In order to reduce the risk and consequences of accidents, theWIPP PIG sets stringent performance requirements for carriers and drivers. TheWIPP PIG strives to reduce the possibility of transportation incidents by imposing stringent driver qualifications and training, requiring strict adherence to relevant regulations, and including provisions in carriers’ contracts that promote safety. The WIPP PIG permits the WGAWIPP Technical Advisory Group to participate in the development of transportation contracts and the carriers’management plans and the technical evaluation of carriers’ proposals. Safety requirements that are incorporated into the contract and management plan include “above minimum regulatory requirements for driver qualifications, driver performance, driver training, carrier performance, inspection requirements, and vehicle maintenance” (ibid., p. I-1). The contracts that DOE currently has with two commercial carriers require that designated trucks and drivers be used for WIPP shipments. TheWIPP transportation contract and carrier management plan include numerous requirements related to driver qualifications and training that go beyond what DOE commits to in the DOE Manual. These are listed in the document “Model Safety Elements in theWIPP Transportation Contract and Corresponding Carrier Management Plan,” and cover areas such as a minimum age and miles logged for drivers, carrier-developed driver training programs, driver pay, substance abuse policies, driver penalties, driver inspections of cargo, and the use of two qualified drivers per shipment (WGA 1996, p. 3). In addition, carriers and drivers must comply with applicable state and federal regulations, including 49 CFR; carry liability insurance; meet CVSA enhanced inspection standards; utilize TRANSCOM and the TRIPMASTER system or the equivalent; maintain a satisfactory rating from the Office of Motor Carriers for the contract period; and possess the authority to operate in all of the states that will be affected byWIPP shipments (ibid., p. 2). Checklists for driver and vehicle are used to verify compliance with these requirements. The WGAWIPP Technical Advisory Group carries out a Compliance Audit Program to ensure that carriers comply with all applicable laws, regulations, and other requirements. DOE’s Carlsbad Field Office ensures that contract carriers undergo performance audits each year; audits are typically conducted by the host state. The expectations that the Midwestern states have for carrier selection and driver/crew compliance for shipments that travel through the region are expressed in the Planning Guide for Shipments of Radioactive Materials through the Midwestern States . The Midwestern states expect that shippers will select carriers with exceptional safety records to transport radioactive materials. The WIPP requirements should be used as the minimum standards for truck drivers. These include requiring drivers to have logged 100,000 miles in a semi-tractor/trailer combination and two years of uninterrupted commercial driving experience in the past five years. Drivers in long-duration shipping campaigns should be trained in CVSA Level VI enhanced inspection procedures, TRANSCOM, and awareness level first responder training. Shippers should also comply with NRC orders related to shipping radioactive materials in quantities of concern, which include background checks for carriers
(MRMTC 2008b, p. 8). For rail shipments, the Midwestern states expect that locomotive engineers transporting radioactive materials will meet the requirements of the FRA’s Locomotive Engineer Certification, and that train crews will have received hazardous materials training (ibid., p.9). It is the Midwestern states’ expectation that shippers will only utilize carriers with satisfactory DOT ratings, and, if the shipper is DOE or one of its contractors, satisfactory ratings from DOE’s Motor Carrier Evaluation Program. Finally, the states expect that if OCRWM is the shipper, the department will abide by all applicable agreements with the states and regional groups. All shippers are expected to share the carrier’s draft management plan to the corridor states for comment in advance of shipments (ibid.). All shipments of transuranic waste to WIPP to date have travelled via truck. In December 2003, the WGAWIPP Technical Advisory Group issued a set of expectations that the Western states have for shipments of transuranic waste that may occur by rail. The “rail expectations” document includes expectations that relate to carrier qualifications. The Western states expressed their general expectation that OCRWM will ensure that rail shipments are conducted using standards, procedures, and protocols that are comparable to those used for truck shipments of transuranic waste. Rail carriers are expected to ensure that trains transporting transuranic waste are operated by qualified crews, and the FRA and/or the WGA lead states will verify that train crews are properly trained, certified, and experienced. Locomotive engineers are expected to meet the Locomotive Engineer Certification requirements. Carriers are expected to meet the requirements of 49 CFR, including the requirement that crew members receive hazardous materials training.
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