Re: DOT Training Requirement (HM126F)

[SMITHCH01@delphi.com]

One more word on 49 CFR Subpart H (HM126F) training.
Recently, a power reactor received a notice of violation on this exact 
issue.  Basically, two shippers received some sort of training on trans-
portation.  The hazmat employer did not certify the employees were trained
IAW 49 CFR 172.704(d)5.  The NRC promptly issued 3 NOV's.      
1) Hazmat Employer did not certify (see above)
2) Incomplete Training Records 172.704 (d)
and 3) Noncompliance with 10 CFR 71.5 ( Compliance With DOT regs).

The power reactor which recieved the NOV's also thought,  "If we have a
certificate of training then we are covered."  This seeming minor point
has been overlooked thus far in the discussions on DOT Training.  NRC
Licensees and agreement state licensees need to clearly distinguish
between a certificate awarded by a third party trainer and the DOT 
required hazmat employer certification.  This cmay be nothing more than a 
letter to the appropriate training file of how each of the DOT required 
training items are addressed.  

Charles Smith 
Applied Radwaste Management,Inc.
(803) 926-8558
smithch01@delphi.com