Friday, December 5, 2008

New NRC Shipment Security Rules

Anyone that thinks TSA is taking rail security too seriously just needs to take a look at the new rules published by the Nuclear Regulatory Commission. These new additional security measures (ASM) apply to Radioactive Material Quantities of Concern (RAMQC), the definition of which is only of concern to shippers of radioactive materials. Before someone ships a RAMQC they have to inform the NRC at least 7 days in advance of the shipment. There are seven elements of information that must be included in the notification, but the list of those items is considered to be ‘Safeguard’ so it cannot be printed in the Federal Register. One could assume that it would include a listing of the material to be shipped, the origin of the shipment, the destination of the shipment, the shipment mode and the shipment route. We’ll have to guess what the other two elements are. The shipper also has to independently verify that the intended recipient has a valid license to possess and use the radioactive materials being shipped. The ‘ship to’ address has to be checked to verify that it is included in the license and is a valid address. A special verification will be done for unusual orders or changes to orders. All verification procedures and results will be documented. Finally, the departure and arrival times of the shipment will be coordinated with the recipient. When these shipments are made by rail, the shipper must prepare plans and procedures for both normal and contingency situations. The plans will include responses to responses to “actual, attempted, or suspicious activities related to theft, loss, diversion, or radiological sabotage of a shipment”. The requirements for that response is also apparently ‘Safeguard’ information and not printed in the Federal Register. This planning process will include notification of and coordination with state officials of states through which the shipment will pass. The state officials will be asked if the State intends to provide escorts for the shipment. Provisions will be made to provide State authorities with the location of the shipment if requested. Those plans and procedures will include communication protocols along with plans for both expected and unexpected loss of communications. Those protocols will address authentication procedures and the use of duress codes. They will also identify designated local law enforcement agency (LLEA) contacts along the route. A communication center must be established (and staffed with properly trained and vetted personnel) that allows for two way communication with the train crew and any escort vehicles. The communications center will have a back-up method of communication using a “diverse method not subject to the same interference factors as the primary capability”. There are a number of other requirements, but they too are ‘Safeguard’ information and could not be printed in the Federal Register. Thank goodness that we are not working with RAMQC. Us chemical types only have to deal with some minor rules for shipping relatively safe and routine materials such as chlorine and fluorine. I’m really glad we don’t deal with anything really dangerous.

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