In Information Notice 92-62, "Emergency Response Information Requirements for Radioactive Material Shipments," the NRC states that, "...Emergency responders will expect this [emergency response] information to be provided within 15 minutes..."
However a DOT/RSPA letter of interpretation (letter to Mr. Andrew C. Rymer, dated April 5, 2001, Ref. No. 00-280 - available thru link on DOT/RSPA hazmat safety web site) states: "We are aware of the Nuclear Regulatory Commission's (NRC) Information Notice 92-62 that was issued... The NRC provided its opinions that emergency responders would want or expect that this information be provided within 15 minutes. It is our opinion that an emergency responder would want the information as quickly as possible and that, in many if not most hazardous materials transportation situations, a delay of 15 minutes would be unacceptable." [emphasis mine].
If not 15 minutes, is there a workable time limit? The letter of interpretation states, " Clearly a few minutes may lapse during a telephone call... However, any delay longer than a few minutes would be unacceptable, as would any delay involving call-back..."
In my opinion, this hard line policy may actually compromise the quality of information provided to incident responders. Obviously, the person most familiar with the shipment cannot be at the emergency response number for the entire duration of a long shipment. The shipper must thus rely on the written information provided to the person monitoring the emergency response phone number. If we later provided more detailed information, could we be cited for undue delay?
I'd be interested in the opinions of any transportation experts out there, as well as information regarding whether anyone who provided the required information within 15 minutes was still cited by DOT, State Police, etc.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com