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HAZARDOUS MATERIALS TRANSPORTATION: LAWS: REGULATIONS. AND POLICY

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By ‘ ST. LQUES5. M0.

Paul Rotnberg
Science Policy Research Division

Congressional Research Service

 

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CRS- 1 IB76026 UPDATE-O5/Ol/86

iSSUE DEFINITION

The transportation of hazardous materials, such as chlorine, nuclear
wastes, liquefied natural gas, and gasoline, can pose a serious risk to
health, safety, and property. Congress has provided the Department of
Transportation (DOT) with the legislative responsibility to ensure the safe
transportation of these materials while not impeding their flow in interstate
commerce. A

The Hazardous Materials Transportation Act (P.L. 93-633), which is
administered by DOT, is among the most significant laws affecting this area
of commerce. Using its authorities, DOT has undertaken major steps to
improve its regulatory program, such as simplifying its regulatory code,
publishing an emergency response guidebook, creating a hazardous materials
information system, and seeking ways to improve its administration. However,
many Federal, State, and public interest and industry officials are concerned
over several aspects of DOT's program, including its enforcement efforts,
emergency response and training capabilities, cooperation with State and
local governments, and regulations affecting the transportation of
radioactive materials.

During the second session of the 99th Congress, several congressional
committees will try to reauthorize the Hazardous Materials Transportation Act
to address these and other concerns.

BACKGROUND AND POLICY ANALYSIS

Under certain conditions, hazardous materials may pose an unreasonable
risk to health, safety, or property when transported in commerce. Common
examples of these materials include liquefied natural gas (LNG), liquefied
petroleum gas (LPG), cleaning compounds, sulfuric acid, ammonia, phenol,
low-level radioactive materials, paint and paint-related compounds, and
gasoline. Because of the widespread use of these materials,. the
transportation of hazardous materials has become a socioeconomic necessity in
our complex society. According to DOT, about 4 billion tons of regulated

hazardous materials are shipped each year. The National Transportation
Safety Board (NTSB) estimates that approximately 250,000 hazardous materials
shipments are made every day. Although the exact volume, nature, and

location of these shipments is unknown, public awareness and concern over
these shipments is increasing.

An extensive network of companies produce, package, ship, and manufacture

vessels or containment systems for hazardous materials. For example, DOT
reports that there are about lO0,000 shippers of hazardous materials and
5,500 manufacturers of cylinders, retesters, and related equipment. Other

groups in this network include the railroad industry, tank truck carriers,
air carriers, the maritime industry, and drum reconditioners.

Most of the time, the transportation of hazardous materials primarily
concerns industry operating under government regulation. However, accidents
involving the release of hazardous materials affect thousands of citizens,
firefighters, police, and other public safety personnel each year and can

CRS- 2 1375025 UPDATE-O5/Ol/86

result in damages totalling millions of dollars each year. According to data
collected by DOT, there were seven fatalities and 242 injuries resulting from
5,512 incidents involving hazardous materials transportation during l984°
Although DOT's data base is incomplete, it is the best system currently
available.

LEGISLATIVE AUTHORITIES OF THE DOT AFFECTING
HAZARDOUS MATERIALS TRANSPORTATION

Congress has provided DOT with several basic sources of authority to deal
with hazardous materials transportation. Using the Transportation of
Explosives Act, the Federal Aviation Act of l958, the Dangerous Cargo Act,
the Ports and Tanker Safety Act, the Hazardous Materials Transportation Act
(HMTA), and the Rail Safety Improvement Act of l974, DOT seeks to ensure
safety to life and property while not impeding the flown of hazardous
materials in commerce.

Of these measures, the HMTA is perhaps the most significant law affecting
this area of commerce. This law (P.L° 93-633) contains provisions which
seek:

-- the removal of statutory restrictions on the
Secretary's authority to centralize DOT's regulatory
activities relating to the safe transportation
of hazardous materials by Various modes;

-- the extension of the Secretary's authority to impose
civil penalties for violations committed in
the rail and highway modes;

~-.a significant increase in the criminal sanctions
for violations of hazardous materials transportation
regulations;

-= provisions of various forms of specific relief
as additional enforcement tools;

=- a broadening of the definition of "commerce"
to include transportation which affects
interstate transportation;

-- an extension of the Secretary's regulatory authority
to the manufacturers of packages and containers
used in the transportation ofghazardous materials;
and

-- authorization for the Secretary to require shippers
and carriers of hazardous materials, and
manufacturers of hazardous materials containers,
to register with the DOT.

DOT has implemented most of the provisions of this Act and has conducted a
multi—faceted program of regulatory development, data collection, training,
and enforcement to promote the safe transport of hazardous materials. For
example, DOT has issued over l000 pages of hazardous materials transportation
(HMT) regulations that affect various aspects of transporting these

CRS- 3 IB76026 UPDATE~O5/Ol/86

'materials, deleted some obsolete requirements, and established uniform

placarding requirements and standardized shipping papers. In the development

its HMT regulations, DOT considers numerous factors including fire (and
explosion) hazards because materials posing this risk have been the cause of
more than 95% of the serious consequences encountered in the transportation
of hazardous materials. On a continuing basis, DOT collects data on HMT
accidents and seeks to improve its methodology for regulatory analysis and
emergency preparedness planning.  

In addition to the transportation laws cited above, Several environmental
laws also affect the transportation of hazardous materials. For example, the
Comprehensive Environmental Response, Compensation, and Liability Act of l98O
(CERCLA), which deals primarily with hazardous releases from various
facilities, also regulates the transportation of.a specific type of hazardous
material, called a "hazardous substance." pTo coordinate the implementation
of HMTA and CERCLA, Congress required the Secretary of Transportation to list
all "hazardous substances," as defined by CERCLA, as a "hazardous material"
under HMTA. Likewise, the Resource Conservation and Recovery Act (RCRA),
which primarily regulates the disposal and transportation of hazardous
wastes, also affects DOT's hazardous materials transportation program. To
coordinate the implementation of RCRA with HMTA, DOT issued a regulation
incorporating EPA's "cradle-to—grave" manifest system and other requirements
for the transportation of hazardous wastes into DOT's HMT regulations.

RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION (RSPA):
GOALS, JURISDICTION, BUDGET, AND SELECTED ACTIVITIES

RSPA, within DOT, serves as the national focal point for coordination and
control of domestic and international shipments of hazardous materials, and
prescribes national safety regulations for hazardous materials
transportation. RSPA issues DOT's HMT regulations, which establish minimum
safety requirements that serve as a floor for industry's own transportation
safety practices. RSPA must balance the often competing interests of
economic feasibility and public safety when it seeks:

-- to minimize the public safety risk inherent
in the transportation of hazardous materials;

-- to reduce the regulatory burden (Federal, State
and local) on commerce; and

-- to prevent the adoption of international safety
standards which would impose non-tariff trade
barriers on American industry.

RSPA does not conduct its program in a vacumm. This DOT Administration
seeks to coordinate its rulemaking activities with other involved Federal
agencies, maintain extensive contacts with industry groups, and deal with the
international aspects of HMT. In developing its regulations, RSPA is
expected to consider the input of the four modal administrations in DOT.

nder the Reagan Administration, RSPA seeks to forge a partnership with State
and local governments to promote safety in the transportation of hazardous
materials. RSPA maintains that the best way to encourage Federal/State
sharing of responsibilities is to promote a national set of .safety
regulations which are uniformly applied and enforced.

CRS- 4 IB76026 UPDATE-05/Ol/86

While RSPA primarily exercises compliance and enforcement authority over
manufacturers, reconditioners, and retesters of DDT specification containers
and intermodal or multimodal shippers of hazardous materials, other parts of
DOT, called "operating administrations," retain jurisdictional responsibility
for enforcement and compliance actions relating to unimodal (one means of)
transportation of hazardous materials. For example, the. U.S. Coast Guard
(USCG) conducts a safety program for hazardous materials transported by
domestic or foreign vessels in U.S. navigable waters, as well as over
hazardous materials located in U.S. port areas. The USCG also issues and
enforces numerous regulations affecting the bulk transportation of hazardous
materials by water. The Federal Railroad Administration (FRA) is responsible
for ensuring safe movement of hazardous materials by railroad, including
loading, unloading, or temporary storage in freight yards. The Federal
Aviation Administration (FAA) carries. out compliance inspections and
enforcement actions relating to air transportation of hazardous materials in
both domestic and international commerce, and the Federal Highway
Administration (FHWA) specifically controls highway movement of hazardous
materials cargo. On occasion, RSPA inspectors will work jointly with
inspectors from the various modes.

Many companies are motivated to obey the DOT regulations for one or more
reasons: to avoid DOT's penalties which can range up to $10,000 per day per
violation, to promote safety in their operations and to protect their
employees, and to avoid increased insurance rates.

As shown in Table I, there does not appear to be any consistent trend

associated with RSPA's appropriations for its hazardous materials program
over the last 8 fiscal years.

Table 1. Approximate Funding Level for RSPA's HMT Program

:1 Appropriation

80 $4.114 million
81 $8.339 million
82 $4.488 million
83 $5.733 million
84 $6.870 million
85 8 $6.114 million
86 $5.602 million
87 request $6.706 million

(From DOT -— note: funding levels after FY83 include

some administrative and "overhead" expenses.)

Cindy Douglass is the Administrator of RSPA, within which DOT's Office of
Hazardous Materials Regulation (OHMR) is located. OHMR is the operating
functional organization that runs RSPA's hazardous materials program. For
FY86, RSPA requested an appropriation of $5.617 million to carry out its HMT
program, including $4.867 million for program operations and $.750 million

for R&D. For FY87, RSPA is requesting an appropriation of $6.706 million tr’

carry out its HMT program, including $5.956 million for operations and $0.750
million for R&D. RSPA has approximately 65 staff positions allocated for HMT
activities.i

CRS- 5 IB76026 UPDATE-O5/Ol/86
Some of the key aspects of RSPA's FY87 budget request include:

-- $370,000 to support RSPA's Hazardous Materials
Information System, which includes a direct
access system with multiple users at different
locations for a variety of analytical, enforcement, and
training purposes.

-- $130,000 for testing of containers and materials in
support of increased enforcement efforts;

-- $185,000 for partial funding of RSPA-sponsored
hazardous material training programs at the
Transportation Safety Institute in Oklahoma City.

—- $20l,000 to support State hazardous material
accident prevention and response programs.

-- $544,000 to undertake a major revision of the l984
edition of the Emergency Response Guidebook and to
‘print 750,000 copies of the guidebook.

-- an increase of 12 staffers in the Office of Hazardous
Materials Transportation.

-- $270,000 for analyzing costs, risks, and impacts of
planned/proposed regulatory activities.

Presented below is a short discussion of three key components of DOT's
hazardous materials program:

-- emergency response capabilities,

—- hazardous materials inspection and enforcement activities, and
-- training and emergency response planning.

Emergency Response Capabilities

DOT has established in Washington, D.C., the U.S. Coast Guard's National
Response Center that can provide emergency response information, collect
information on certain hazardous materials transportation accidents, and
notify specific State and local safety officials regarding major accidents.
In FY86 and FY87, RSPA intends to continue its support of technical
assistance to local authorities responding to hazardous materials accidents
and emergencies partly through the response center.

During the last few years, DOT has provided funds for guidebooks and
training packages used by emergency personnel and those planning responses to
hazardous materials accidents. The most widely distributed of these is "The
Emergency Response Guidebook: Guidebook for Hazardous Materials Incidents."
DOT has distributed about 1.5 million copies of this document, which provides
brief information on some of the potential health hazards and on some of the
potential fire or explosion hazards of various materials as well as selected

mergency action steps, including some first aid measures. According to DOT,
the Emergency Response Guidebook serves as a guide for initial actions to be
taken by emergency services personnel to protect themselves and the public
primarily when they respond to the initial phases following incidents
involving hazardous materials. Furthermore, DOT specifies that its guidebook

cRs- 6 IB76026 UPDATE-05/01/86

is primarily designed for use at a hazardous material incident occurring on a
highway or a railroad; however, DOT states the Emergency Response Guidebook
"will, with certain limitations, be of use in handling incidents in other
modes of transportation and at facilities such as terminals and warehouses."
DOT does not claim that its recommendations are necessarily adequate or
applicable in all cases, and stresses that the guidebook is not intended to
be a substitute for a responder's own knowledge or judgment. The guidebook,
however, specifies that its recommendations are those most likely to be
applicable in the majority of cases and that its guides (Nos. ll to 75 in the
l984 edition) cover hazardous materials taken, one at a time, and spilled or
involved in a fire. The Emergency Response Guidebook should be consulted
directly for instructions and information on how to use it properly.

DOT estimates that the Emergency Response Guidebook is used by some 30,000
fire departments, 30,000 police departments, and at least 10,000 other
response organizations. RSPA is revising and updating the 1984 edition of
the guidebook for publication and distribution in 1987.

Hazardous Materials Inspection and Enforcement Activities

DOT's hazardous materials compliance and enforcement effort is designed to
reduce the number of incidents and the risk of catastrophic events that may
result from violations of Federal code. within its operating administrations
(e.g., FRA, FHWA, FAA), DOT has about 60 full-time and about 980 part-time
hazardous materials inspectors and in the MTB there are about 7 intermodal
inspectors. DOT points out that the States are extending the national
enforcement capability by some 500 inspectors, some of whom are policemen.

During the early to mid-1980s, DOT bolstered State enforcement efforts
through its States Hazardous Materials Enforcement Development Program
(SHMED), which sought to foster Federal/State partnerships in inspection and
enforcement. activities within existing public safety agencies. By
contractual agreement, DOT provided technical and financial support to States
that enacted legislation providing for adoption of the Federal regulations in
this area. In 1982, DOT expanded the program from 5 to l6 States; DOT
expanded the program to about 26 States during FY85, with funding ending at
the end of FY85. To promote uniformity in the inspection process, RSPA
developed and published a Hazardous Materials Inspection Guide.

DOT has incorporated the SHMED program into its new motor carrier safety
enforcement program, created under the Surface Transportation Assistance Act
of 1982, which authorizes grants and technical assistance to States to
develop and administer highway transportation safety programs, including
aspects affecting hazardous materials transportation. Although DOT is
devoting increased attention to its enforcement responsibilities and to
Federal/State cooperation in this area, the large number of highway carriers
of hazardous materials and the frequency of their shipments make it extremely
difficult to assure acceptable levels of regulatory compliance.

Some critics of DOT's program have stated that Federal enforcement and
training efforts are thinly spread and have been only moderately successful.
Accordingly, they have recommended that the HMTA be amended to vest primary
enforcement and training authority in State governments and that additional
Federal assistance be provided tof States to cope with their increased
responsibilities in these areas.

CRS- 7 IB76026 UPDATE-05/Ol/86
Training and Emergency Response Planning Aztivities

One way to promote safety in the transportation of hazardous materials is
-o provide appropriate training to both public and private sector personnel.
For example, DOT's training of Federal, State, and local inspectors helps
promote effective and consistent enforcement of nationally uniform safety

regulations. In FY87, RSPA plans to sponsor 56 classes in six enforcement
areas of HMT regulations for l,880 Federal, State, and local governmental
employees. Likewise, training of shippers and carriers can improve

compliance with DOT's HMT code and can assist in prompt emergency response to

many accidents. Although DOT has supported some training courses for
emergency responders, the Department has generally turned these activities

_over to the Federal Emergency Management Agency (FEMA). This agency conducts

hazardous materials training for about 1,000 firefighters a year at their

,training academy in Maryland and for about another 2,000 or more who receive

training annually at other locations. Some of those trained by FEMA return
to their home bases and train others.

Despite these activities, some groups argue that local governments lack
appropriate training, information, and equipment to respond to incidents
involving HMT. In order to obtain accurate information on the current state
of affairs, Congress has required (in P.L. 98-559) that DOT's Secretary and
FEMA's Director conduct several evaluations of various training and emergency
response planning programs. These Federal agencies are currently examining:

(1) Programs conducted by Federal, State, and local
agencies and private organizations which
provide training to shippers, carriers,
inspectors, and enforcement personnel
involved in the transportation of hazardous’
materials with respect to compliance with, and
enforcement of, hazardous materials regulations;

(2) Programs conducted by Federal, State, and
local agencies and private organizations which
provide training to agencies or
organizations responsible for responding
to incidents involving transportation of
hazardous materials; and

(3) Planning programs conducted by Federal, State,
and local agencies and private organizations for
responding to hazardous materials incidents.

P.L. 98-559 also requires DOT's Secretary and FEMA's Director to provide
Congress with:

(1) A description of existing planning programs
for responding to incidents involving transportation of
hazardous materials;

(2) A description of existing Federal and private
programs to provide day-to-day technical and
operational response assistance to State and/or
local governments;

(3) A description of Federal, State, private and
local training programs for responding

CRS- 8 IB76026 UPDATE-O5/Ol/86

to incidents inVolving%hazardous
materials and for compliance with,

and enforcement of, rules, regulations,
standards, and orders promulgated by the
Department of Transportation; and

(4) Recommendations concerning methods of funding
such training programs.

These evaluations were due Aug. 30, l985, but as of Mar. 6, l986, they
have not yet been received. The information and recommendations contained in
these reports may be useful to Congress when it considers amendments to the
Hazardous Materials Transportation Act.

Legislation (H.R. 966) has been proposed to create regional training
centers (see Legislation section below).

ISSUES CONCERNING HAZARDOUS MATERIALS TRANSPORTATION

During the second session of the 99th Congress, it seems likely that
several congressional committees will attempt to reauthorize or amend the
HMTA. To help guide their actions, these committees should have, by early
l986, the results of four major reports focusing on various aspects of the
Federal role in hazardous materials transportation safety. These reports are
being prepared by the Office of Technology Assessment, the National Hazardous
Materials Transportation Advisory Council, an internal DOT task force, and
the joint DOT/FEMA reports described in the previous section. I

Presented beloweare brief summaries Of selected issues that might Del

considered as these committees comtemplate changes in HMTA. These issues,
some of which will also be dealt with in the studies previously mentioned,
include: transportation of radioactive materials and Federal, State, and
local government involvement; transportation of hazardous materials and
Federal/State relationships; pre-notification requirements for hazardous
materials shipments, routing of hazardous materials shipments, and training
and emergency response activities.

Radioactive Materials Transportation
(1) Federal Agency Involvement

The three primary Federal organizations affecting nuclear materials
transportation are DOT, NRC, and DOE.

Department of Transportation. DOT issues regulations that provide minimum
safety standards or,I in some cases, guidelines for routing, packaging,
labeling, marking, placarding, loading, and unloading of many nuclear
materials shipments.

The Department focuses its efforts on driver training, truck, airplane,
and rail safety standards and other factors affecting transportation safety'
and performance standards for different types of packages or containers,
including packages containing limited quantity, low—specific activity, and
Type A nuclear materials. In most cases, DOT designs its regulations to be
uniform with those issued by the International Atomic Energy Agency. DOT

CRS- 9 IB76026 UPDATE-O5/Ol/86

also seeks to coordinate its regulatory and enforcement efforts with those of
other Federal organizations, especially NRC.

Nuclear Regulatory Commission. NRC also regulates various aspects of
transporting nuclear materials, but its regulations extend beyond those of
DOT and specify additional requirements and control procedures for some of
the most potentially dangerous nuclear materials shipments. For example, NRC
issues regulations for packaging, preparing for shipment, and transporting
licensed materials. The Commission also issues procedures and standards for
NRC approval of packaging, and shipping procedures for fissile materials and
for specified quantities of other licensed materials. To promote safety, NRC
relies principally upon the engineered and designed features of the transport
casks or containers. Like DOT, NRC has also made many of its regulations
uniform with those issued by the International Atomic Energy Agency. The
Commission requires its licenses to notify affected State governors (or their
designees) before shipping large quantities of radioactive wastes, including
spent fuel across State lines. NRC requires its licensees to supply
information on the name, address, and telephone number of the company
shipping the material; a description of the material to be transported; and
estimated periods of arrival at State boundaries. (This represents the first
time a Federal agency has required pre-notification of a shipment of any
hazardous material.) For security and safety reasons, information on
shipments of certain types of spent fuels are withheld from the public.

Department of Energy. DOE participates in a variety of activities that
involve nuclear materials transportation. As the lead agency assigned to

-develop a national plan for low-level nuclear waste management and disposal,

DOE must deal with several safety issues, including concerns regarding

ackaging and shipping. In addition, the Department regulates its
contractors transporting nuclear wastes at the National Laboratories, weapons
production facilities, and uranium enrichment plants. The Department

generally follows NRC and DOT regulations, but_in some cases, DOE exempts its
contractors from placarding requirements to ensure that the identity of
weapons-grade materials remains secret. DOE and its predecessor
organizations also have sponsored research, such as the work conducted at
Sandia National Laboratories, to study how spent fuel casks behave under
accident conditions.

During the next 20 years, the Energy Department is likely to increase its
involvement in the transportation of spent fuels. As a result of the Nuclear
waste Policy Act (NWPA) of 1982, DOE may assume responsibility for
transporting some high-level nuclear wastes and spent nuclear fuel materials
to either temporary or permanent waste disposal sites as well as a multiple
retrieval storage facility. when transporting these nuclear wastes, DOE must
use private carriers whenever possible.

In September 1985, DOT and DOE signed a memorandum of understanding (MOU)
to delineate their respective responsibilities and establish common planning
assumptions regarding the transportation requirements of the NWPA. According
to the MOU, DOE's Office of Civilian Radioactive waste Management will
arrange for the transportation of spent fuel and high-level radioactive
wastes resulting from the implementation of NWPA. Furthermore, the movement
of these nuclear materials is to be performed in full compliance with all
ipplicable Federal regulations and with state and local laws and regulations
that are not inconsistent with the HMTA or its regulations. The MOU
specifies that development and execution of an effective transportation
safety regulatory compliance and inspection policy is to be a common area of
interest between DOT and DOE.

CRS-l0 1375025 UPDATE-05/01/86

DOE also conducts the Radiological Assistance Program which is part of the
Federal Government's emergency response system for nuclear materials
shipments. This DOE effort seeks to minimize personnel injury and property
loss and to protect public health and safety from serious accidents involving
nuclear materials transportation. DOE provides this advice and assistance
whenever it believes such action is necessary or upon request from NRC, its
contractors, State licensees, or other governmental agencies.

With respect to organizational concerns, Congress continues to examine the
extent of coordination among the involved Federal agencies and whether they
are effectively and efficiently conducting their missions pertaining to
nuclear materials transportation safety.

(2) Contrasting Views on Safety

The prospects for substantially increased shipments of nuclear materials
during the next 20 years raises the question: Can these materials be
transported safely? A

The View That Nuclear Materials Transportation Is Conducted Safely.
spokesmen for the Federal Government and the nuclear power industry as well
as many experts in the scientific community maintain that nuclear materials
can be transported safely, provided that Federal regulations and control

procedures are strictly obeyed. To support their view, they point to an
extensive regulatory system designed to promote safety in every aspect of
transportation, including packaging, labeling, shipping, routing, and

.unloading. These spokesmen maintain that adherence to Federal regulations is

ensured by an elaborate system of inspections and tests.

The accident record for nuclear materials transportation is often cited as
evidence that this transportation activity is conducted safely. According to
Robert Jefferson, formerly of Sandia National Laboratories, who has conducted
more than 10 years of research in this area, the safety record for shipping
nuclear materials far surpasses that of any hazardous materials being moved
in the world today. His data indicate that in the l0-year period between
l97l and 1980 inclusive, there were l0l accidents involving l,ll4 packages
containing all types of radioactive materials of which 1,008 packages did not

release any materials. According to Mr. Jefferson, this safety record
indicates a 99% survivability rate for those packages not even designed to
survive accidents and 100% for those designed to survive an accident. In

addition, the Atomic Industrial Forum, Inc., an association of companies
involved in nuclear energy, points out that in more than 5,000 shipments of
spent fuel assemblies in the United States over the past 20 years there has
not been a release of radiation, despite four serious road accidents.

As one measure of safety and the effectiveness of its program, DOT also
cites the excellent accident and release record for nuclear materials
shipments. Lee Santman, former Director of the Materials Transportation
Bureau of DDT, reports that about 3 million packages containing radioactive
materials are transported annually. (About one million of these each year
are associated with medical treatment and diagnosis, about one-half of one
million each year are associated with the fuel cycle, and about 1.5 million
each year are for industrial research purposes.) Although DOT receives a‘
average of about 75 reports annually on transportation incidents involving
these materials, the majority -- an average of 65 per year -- involve
suspected contamination or questions about container integrity rather than
the actual release of radioactive materials. According to Mr. Santman, this

CRS—ll IB76026 UPDATE-05/0l/86

safety record gives DOT the level of confidence to continue requiring
adherence to the Nuclear Regulatory Commission's standards for casks and

ther packages. Furthermore, DOE points out that the casks used to transport
spent fuel are designed to prevent the release of materials and radiation
under severe accident conditions.

The National Transportation Safety Board (NTSB), an independent agency of
the Federal Government that seeks to improve Federal safety regulations,
maintains that the harm from exposure to radiation that has occurred during
transportation appears to be miniscule. NTSB notes that more analytical
testing and control efforts designed to assure minimal risks have been
devoted to radioactive materials than to any other hazardous material ever
shipped. This Federal safety agency concludes that the emergency response
plans for nuclear materials transportation are the most comprehensive yet
formulated for handling hazardous materials emergencies, and these plans have
served as models for many non-radiological contingency plans.

The View that Nuclear Materials Transportation is Unsafe Many public

interest groups, local communities, and others believe that the
transportation of nuclear materials as currently practiced is unsafe. For
example, Dr. Marvin Resnikoff, speaking for the Council on Economic

Priorities, a public service research organization, maintains that shipping
containers or casks are poorly designed and constructed and cannot withstand
realistic highway and rail accidents. His analysis indicates that: (l)
NRC's cask tests are outmoded; (2) the integrity of the casks can be
violated; (3) Federal certification tests can be inadequate and incomplete;
and (4) some of the experiments and tests conducted at Sandia National
’aboratories to confirm the structural integrity of the casks are flawed.
nerefore, Dr. Resnikoff urges Congress to recall the present generation of
shipping containers before a major accident occurs. Instead of transporting
high-level nuclear materials, he recommends that dry storage casks should be
used at reactor sites.

Dr. Resnikoff maintains that DOT has underestimated the probability and
consequences of a nuclear materials transportation accident. He states:
"...the casks now in use threaten accidents which, while unlikely: Would be
as serious as a meltdown at a nuclear reactor. Many more people and much
more property could be affected by a cask accident than by a reactor
meltdown, because a cask accident could occur in the midst of a populous
city." His studies indicate that in 1990 there will be five transportation
accidents involving high-level nuclear shipments and that in 2,000 27 such
accidents will occur. Most of these accidents will be minor; some may be
severe.

Many people who criticize the current regulatory system for nuclear
materials transportation are concerned that these shipments are subject to
sabotage and are sometimes misplaced or stolen in commerce. They frequently
quote reports by Sandia National Laboratories which indicate that access to
shipments of irradiated spent fuel rods would be possible for an adversary
intent upon sabotage or theft and that any such attack can be expected to
take place in densely populated areas.

The issue of the safety of nuclear materials transportation will probably
lever be resolved to the satisfaction of all involved parties; nevertheless,
it is likely to remain a key concern as Congress continues to oversee
implementation of the NWPA.

CRS=l2 IB76026 UPDATE-O5/Ol/86
(3) State and Local Government Involvement

One of the most controversial regulations issued by the DOT is HM—l64,
which is a highway routing regulation for certain radioactive materials.
This regulation requires motor carriers of "highway route controlled
quantity" radioactive materials, including spent nuclear fuel rods, to
operate over the Nation's interstate system in such a manner as to reduce
time in transit, and that an interstate system beltway or bypass going around
a city should be used when available. State and local restrictions, such as

absolute bans on the transportation of these materials in their
jurisdictions, have been judged by DOT to be inconsistent with HM=l64 and
therefore would be preempted under P.L. 93-633. Nevertheless, HM-l64 does
offer some flexibility to the States. For example, it allows a "State

Routing Agency" to designate preferred routes other than the interstate
routes based on analysis of certain risk factors and careful consideration of
the views of affected city and county officials. DOT maintains that the
States have the resources to conduct routing analyses and can consider local
viewpoints. \To assist the States in their selection process, DOT has issued
guidelines prescribing methods for selecting preferred routes. Many
municipalties have questioned the usefulness of HM-164 since they claim safer
shipping alternatives are available. CEP recommends that DOT should allow
routing and alternate shipping methods that avoid population centers and
sensitive environmental areas and should notify communities of impending
shipments.

After the U.S. Supreme Court declined to hear New York City's appeal from
a U.S. Circuit Court decision upholding the validity of HM-164, the city
applied for a non-preemption determination under under Section ll2(b) of the
HMTA, however, DOT denied this request and HM-164 remains in effect.

Additional information of conflicts between Federal and State regulations
regarding the transportation of other types of hazardous materials is
presented in Issue (4), below.)

Several bills such as H.R. llO5. H.R. ll46, H.R. 1695, and H.R. 2938, if
enacted, would change Federal policies affecting nuclear materials
transportation. These bills are summarized in the Legislation section.)

Federal and State Relationships in Hazardous Materials Transportation

There is much evidence of increasing conflict over Federal-State
jurisdictions and relationships concerning the transportation of hazardous
materials. Three factors contributing to the current situation include:
questions regarding DOT's pre-emption authority, limited enforcement of
Federal regulations; and the length and complexity of Federal regulations.

Many “local and city governments have issued their own regulations
affecting the transportation of hazardous materials; these regulations
sometimes differ substantially from DOT's regulations. (For example, see
issue (3) above). Local officials argue that their regulations are needed to
meet the transportation demands and safety conditions specific to local
areas. However, industry officials maintain that conflicts and discrepancies
among the various governmental regulations lead to added exposure to chemicai
risks, disruptions in both local and interstate transportation of hazardous
materials, and unintentional non-compliance because shippers and carriers
cannot possibly know and obey all the different regulations.

cns-13 1375025 UPDATE-O5/O1/86

According to of P.L. 93-633, ithe Secretary of Transportation has the
authority to preempt State and local regulations if they are found to be

consistent with HMTA or regulations (49 CRF Parts l7l—l79) issued pursuant
to this Act. It appears that Congress did not intend for the HMTA to occupy
the regulatory field so completely as to preclude State or local involvement.
According to S.Rept. 93-1192, Congress intended this pre-emption provision
"to preclude a multiplicity of State and local regulations and the potential
for varying as well as conflicting regulations in the area of hazardous
materials transportation." However, the Secretary of Transportation may
waive preemption of an inconsistent State or local requirement upon a showing
that such a "requirement offers an equal or greater level of safety and does
not unreasonably burden commerce." Many industry and governmental officials
want to develop an improved Federal pre-emption process; however, working out
the details of such process has proved difficult. The Secretary has stated
that the Department prefers not to seek changes in the present law, but it
may have to support a stronger pre-emption authority if local communities
make the current system impractical (Hazardous Materials’ Transportation,
September l982). The NTSB does not advocate or oppose Federal pre-emption,
but if pre-emption occurs, it wants "to protect the interest of those who
want to look after safety and to be sure [their concerns] are not overridden
carelessly in the process of protecting the economic interests of the
hazardous materials transportation industry" (Hazardous Materials
Transportation, July l982).

A second factor affecting Federal-State relations is concern by some
groups over the effectiveness of the enforcement of Federal regulations.
This issue is discussed above in the section dealing with inspection and

nforcement activities.

with respect to the third factor, the clarity and readability of Federal
hazardous materials transportation regulations have an important bearing on
their effective enforcement. Many industry and State officials have
complained of the complexity and length of the existing DOT regulations and

have suggested that simplifying and consolidating the regulations wouldd

greatly aid in understanding and either enforcing or obeying the regulations.

Despite the complexity of the regulations, most of the States have adopted.

all or part of 49 CFR into their own State code.

RSPA is currently undertaking several program activities designed to
improve Federal-State—local relationships in the hazardous materials area.
In FY86, RSPA initiated with DOT's Bureau of Motor Carrier Safety the
"COHMED" workshops. Through these workshops, Federal and State officials
responsible for hazardous materials transportation are supposed to share
information that may lead to better and more uniform regulatory efforts.
Other workshop topics deal with emergency response and nuclear materials
transportation.

Three other intergovernmental concerns are addressed below:
(1) Pre-Notification Requirements for Hazardous Materials Shipments

An increasing number of State officials want to be notified before certain
hazardous materials are transported across their State boundaries. These
fficials maintain that such information would aid in their response to
emergencies associated with the transportation of these materials. They also
claim that pre-notification would be useful in providing suggestions for
rerouting shipments, if necessary, because of weather or other conditions.
Industry is concerned over the additional costs that would be incurred as a

CRS-14 1375025 UPDATE=O5/Ol/85

result of meeting pre-notification requirements.

(2) Routing of Hazardous Materials

Federal, State, and local governments have had disagreements over the
routing of hazardous materials shipments. DOT maintains that the routing of
these shipments is an appropriate activity for a local government so long as
it does not unilaterially export risks to its neighbors. DOT wants
neighboring jurisdictions affected by a regulation of another community to be
included in that community's decision=making process, thus hopefully ensuring
the enhancement of safety for the region as a whole.

with respect to the highway mode of transportation, DOT's regulations
specify that "unless there is no practicable alternative, a motor vehicle
which contains hazardous materials (except wradioactive materials) must be
operated over routes which do not go through or near heavily populated areas,
places where crowds are assembled, tunnels, narrow streets, or alleys." DOT
does not consider "operating convenience" as a basis for determining whether
it is practicable to operate a motor vehicle is accordance with this
regulation.

(3) Training and Emergency Response Activities

Many State and local governments have complained that they have inadequate
funds to prepare and respond properly to hazardous materials emergencies
within their jurisdictions. Several proposals have been set forth to address
this situation, including the creation of either an emergency response trust
fund or a non-profit foundation.

Emergency Response Trust Fund. A coalition of various State and local
governmental organizations and industry groups have proposed the creation of
a mandatory registration program with a user fee mechanism for the funding of
hazardous materials transportation emergency response planning, training, and
equipment needs. This trust fund would be supported by annual fees "imposed
on all hazardous materials shippers, carriers, and potentially container
manufacturers. DOT would administer the trust and distribute its funds to
states through a grant-in-aid program, with the requirement that 5d% of the
funds be passed through to local governmental units.‘ Despite strong support
for this proposal among some groups, DOT does not consider this concept as
the most effective solution to the problems facing State and local
governments. DOT maintains that this proposal would impose a new tax on
industry and it would impose additional paperwork burdens (and associated
cost impacts) on the Department and industry.

Non-Profit Foundation. DOT proposes that the private sector create and
fund a non-profit foundation to provide funds in the form of grants to State

and local agencies for training first responders. The proposed foundation
would also support a staff to facilitate communication with States and
localities regarding emergency response preparedness and training. DOT

suggests that those companies involved in the transportation of hazardous
materials could make voluntary contributions totalling $10 million per year
for 3 years to support the foundation.

LEGISLATION

H:R. 966 (Florio)
Amends the Hazardous Materials Transportation Act to provide for the

cns-15 IB76026 UPDATE-05/01/86

establishment of regional training centers to train State and local personnel
to: (1) respond to hazardous materials transportation accidents; and (2)

iforce State and local hazardous materials transportation requirements.
introduced Feb. 6, 1985; referred to Committees on Energy and Commerce and on
Public Works and Transportation. Executive comment requested from DOT, NTSB,
and OMB Feb. l9; comment received from NTSB Apr. 10, 1985.

H.R. 1105 (Biaggi)

Radioactive Materials Transportation Safety Act of 1985. Amends the
Hazardous Materials Transportation Act of 1975 to prohibit the transportation
of any controlled quantity of radioactive materials by public road or highway
through or into a city with a population of 50,000 or more. Introduced Feb.
19, 1985; referred to Committee on Public Works and Transportation.
Executive comment requested from DOT, NTSB, and OMB. Comment received from
NTSB Apr. 10, 1985. I

H.R. ll46 (Weiss)

Hazardous Materials Transportation Act Amendments of 1985. Amends the
Hazardous Materials Transportation Act to provide for the establishment of
regional training centers to train State and local personnel to: (1) respond
to hazardous materials transportation accidents; and (2) enforce State and
local hazardous materials transportation requirements. Introduced Feb. 19,
1985; referred to Committees on Public works and Transportation and on Energy
and Commerce. Executive comment requested from DOT, NTSB, and OMB. Comment
received from NTSB May 8, 1985.

H.R. 1695 (Oakar)

Nuclear waste Transportation Safety Act of 1985. Establishes certain
.estrictions on the transportation of high-level radioactive waste and spent
nuclear fuel. Introduced Mar. 25, 1985; referred to Committees on Public
works and Transportation, on Energy and Commerce, and on Interior and Insular
Affairs. Executive Comment requested from DOT, NTSB, and OMB Apr. 8.
Referred to Subcommittee on Surface Transportation.

H.R. 1978 (Torres)

Hazardous waste Safety and Technology Incentive Act of 1985. Amends the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
to require States to develop hazardous waste disposal or treatment plans
adeuqate for the needs of the next 20 years. Provides grants, loan
guarantees, and demonstration projects to encourage the development of
advanced waste disposal technology and the enforcement of transportation of
hazardous waste requirements. Introduced Apr. 3, 1985; referred to
Committees on Energy and Commerce, Public Works and Transportation and
Science and Technology.

H.R. 2118 (Kramer) 6

Defense Hazardous Materials Emergency Act of 1985. Directs the
Secretary of Defense to establish a 24-hour toll-free telephone service in
the Department of Defense to provide emergency information and assistance to
government authorities in the event of an accident involving hazardous

material transported by or for the military. Introduced Apr. 18, 1985;
referred to Committee on Armed Services. Executive comment requested from
DOD Apr. 23. Referred to Subcommittee on Military Installations and

facilities. Executive comment requested from DOT June 11, 1985.

H.R. 2524 (S. Morrison)
Federal Nuclear Waste Disposal Liability Act of 1985. Amends the Atomic
Energy Act of 1954 to‘ provide total Federal indemnification for public

CRS-16 IB76026 UPDATE=O5/01/86

liability claims arising out of nuclear incidents relating to Federal

storage, disposal and related transportation Of high—1eve1 radioactive waste’

and spent nuclear fuel. Introduced May 15, 1985; referred to Committees on

Energy and Commerce and on Interior and Insular Affairs. Hearings held Juned

4 and July 8 (Waterford, Conn.), 1985. Subcommittee consideration and markup
Oct. 29, Nov. 19, Dec. 3, and Dec. 10, 1985.

H.R. 2938 (Green)
Radioactive Materials Transportation Protection Act of 1985. Amends the

Hazardous Materials Transportation Act to direct the Secretary of
Transportation, when route determinations are made for the shipment of such
material, to file an environmental impact statement. which includes

consideration of alternative modes of transporting a controlled quantity of
radioactive materials into or through a high-density metropolitan area.

Introduced July 9, 1985; referred to Committee on Public works ..and

Transportation. Executive comment requested from DOT, NTSB, and OMB.
Comment received from NTSB Aug. 5, 1985.

S. 1162 (Hart)

Nuclear waste Policy Improvements Act of 1985. Amends the Nuclear Waste
Policy Act of 1982 to require that the nomination of sites for repositories
of high-level radioactive waste be accompanied by an environmental assessment
which includes the environmental impact of transporting high—1evel
radioactive waste and spent nuclear fuel through the region surrounding such
site. Introduced May 16, 1985; referred to Committee on Environment and
Public works.

S. 1225 (Simpson)

Price—Anderson Act Amendments of 1985. Amends the Atomic Energy Act) of

1954 to establish an indemnification procedure for full compensation of the
public in the event of extraordinary nuclear accidents which result from
activities undertaken under contract with either the.Department of Energy or
the Nuclear Regulatory Commission. Introduced May 24, 1985; referred to
Committees on Environment and Public works and on Energy and Natural
Resources. Executive comment requested from the Dept. of Energy and from
OMB. Hearings held June 25, 1985.

HEARINGS

U.S. Congress. House. Committee on Interstate and Foreign
Commerce. Subcommittee on Transportation. Authorization
for the Hazardous Materials Act for fiscal year 1980.
Hearing on H.R. 3502, 96th Congress, 1st session. Apr. 10,
1979. Washington, U.S. Govt. Print. Off., 1979. 74 p.

"Serial no. 96-33"

U.S. Congress. House. Committee on Merchant Marine and Fisheries.

Subcommittee on Coast Guard and Navigation. Oil and

hazardous substances liability. Hearings, 96th Congress,

lst session. [washington, U.S. Govt. Print. Off.,] 1979. 423 p.
Hearings on Oil pollution liability (H.R. 29, H.R. 85)

Mar. 13, 14, 1979. Hearings on Marine transportation of

hazardous substances, July 31, Sept. 13, 1979.
"Serial no. 96-16"

U.S. Congress. Senate. Committee on Commerce, Science, and
Transportation. Senate. Reauthorization of hazardous

REPORTS

cns-17 IB76026 UPDATE-O5/Ol/86
materials transportation programs.
lst session. Apr. 24, 1979. Washington,

Off., 1979. 71 p.

Hearing,
U.S.

96th Congress,
Govt. Print.

AND CONGRESSIONAL DOCUMENTS

U.S.

Congress. House. Committee on Government Operations.
Improving the effectiveness of the Bureau of Motor Carrier

safety and its enforcement of hazardous materials regulations.
Nov. 17, 1983. Washington, U.S. Govt. Print. Off., l983.
89 p. (99th Congress, lst session. House. Report no. 98-562)

Congress. Senate. Committee on Commerce, Science, and
Transportation. Hazardous materials transportation: a review
and analysis of the Department of Transportation's regulatory

program. April 1979. Washington, U.S. Govt. Print. Off.,
l979. 251 p.

At head of title: 96th Congress, lst session. Committee
print.

Congress. Senate. Committee on Commerce, Science, and
Transportation. Hazardous materials transportation:
a review and analysis of the Department of Transportation's

regulatory program. Prepared by William Jennings and

Paul Rothberg, Congressional Research Service, U.S. Library
of Congress. April I979. Washington, U.S. Govt. Print.
Off., 1979. 251 p.

At head of title: 96th Congress, lst session. Committee
print.

CHRONOLOGY OF EVENTS

lO/O4/85 --

O9/16/85 --

O9/O9/85 --

RSPA issued a final rule that requires all motor
vehicles, rail cars, portable tanks, and freight
containers carrying specified highly volatile
liquids to display "poison" placards, and that
shipping labels and shipping papers carry the
warning "Poison Inhalation Hazard". According
to DOT, this regulation "will assure that MIC and
other volatile liquids are carried in stronger
containers to reduce the risk of a discharge in
the event of an accident."

RSPA proposed HMT regulations to improve the

safety of tank trucks that carry hazardous gases

and liquids. The proposed rule would require many
truck cargo tanks to be retrofitted with stronger
manhole cover assemblies and improved pressure
relief valves. This proposed regulation is designed
to reduce the risks of fire, major leakages, and
other hazards in overturn accidents.

RSPA denied New York City's request for a waiver of
of HM-164 which governs the highway routing of spent
nuclear fuels. RSPA ruled that New York City had
not demonstrated that HM-164 fails to provide an

O5/O6/82 --

O3/l7/Bl --

Ol/l9/81 --

l2/ll/80 --

O8/OO/78 ==

CRS-l8 IB76026 UPDATE-O5/Ol/86
adequate level of safety because of the unique

circumstances in that city.

NRC's pre-notification requirements for large-quantity
radioactive wastes and spent nuclear fuels shipped in
DOT Type B packages became effective.

NTSB, at the request of the Senate Appropriations
Committee, completed a safety effectiveness

evaluation of Federal and State enforcement efforts

in the area of bulk hazardous materials transportation
by commercial motor vehicle.

DOT issued final regulations establishing routing and
and driver training requirements for highway carriers
of large quantity packages of radioactive materials.

President Carter signed the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (also
known as the "Superfund Law") that reimburses States and
municipalities for waste cleanup costs of certain
hazardous materials. It also affects transportation
activities involving some hazardous materials.

Nuclear Regulatory Commission certified to Congress

that a safe container for air transport of plutonium

had been developed by Sandia Laboratories. The

container is designed to transport up to two kilograms

of plutonium and is intended not to rupture if the aircraft
crashed and exploded.

ADDITIONAL REFERENCE SOURCES

Analysis of NEPA/CEQ requirements with respect to nuclear materials

transportation;
National Laboratories for the U.S.

1982.
D.C.

May 1985.

final report. Prepared by the Sandia
Dept. of Energy. Aug. 31,
International Energy Associated Limited, Washington,

83 p. (SAND85-7161, IEAL-l89.TTC-0227,

unlimited release UC-71)

Assessment of State and local notification requirements for the
transportation of radioactive and other hazardous materials;

final report.

A.

167 p.

Broder,

Council on Economic Priorities/Marvin Resnikoff.
gamble:
New York:

Dugoff,

Henry Schilling,
Research Centers,
for the U.S.
Laboratories.

David S. ‘
Washington Post.

Howard.

Prepared by Dwight Dively, Frederick
and Elaine Shen, Battelle Human
and John Allen, Battelle Columbus
Dept. of Transportation and the Sandia

Jan. ll, l985. Seattle, Washington,

(BHARC°300-85=OOl)

Morris,
Affairs
Laboratories,
National
1985.

U.S. gets ultimatum on nuclear waste.

July ll, l979.

The next nuclear
transportation and storage of nuclear waste. l983.

378.

Testimony before the Senate Committee on Commerce,

CRS-19 IB76026 UPDATE-O5/O1/86
Science, and Transportation. July 13, 1983. (unpublished)
Federal Emergency Management Agency. Fundamentals course for

radiological monitors; student manual. [Washington]
Sept. 1984. (SM-81)

Futter, Jeffrey L. Transportation of radioactive materials -= a
utility view. Long Island Lighting Company. Mineola,
New York. Atomic Industrial Forum, Inc. Kansas City,

Missouri. Feb. 26, 1979. 11 p.

Gillette, Robert. Inexpensive devices could avert major rail
mishaps. Los Angeles times. Apr. 2, 1978.

----+ Railroad holocausts linked to jumbo tank car defects.
Los Angeles times. Apr. 2, 1978: 1. '

National Transportation Safety Board. Safety effectiveness
evaluation -- Federal and State enforcement efforts in
hazardous materials transportation by trade NTSB—see 81-2.
Feb. 19, 1981. 109 p.

Rawls, Rebecca. Chemical transport -- coping with disasters.
C and EN. Nov. 24, 1980: 20-30 p.

Siting of an MRS facility: identification of a geographic

region that reduces transportation requirements.

Prepared for the U.S. Dept. of Energy by G.M. Holter

and J.L. Braitman, Pacific Northwest Laboratory,

operated by the U.S. Dept. of Energy by Battelle
Memoria1'Institute. April 1985. [111 p. (PNL-5424, UC-85)

The transportation of nuclear materials. Prepared by
Theodore A. Wolff, Sandia National Laboratories, for the
U.S. Dept. of Energy. December 1984. 60 p.
(SAND84-O062.TTC—0471, unlimited release UC-71)

Transportation. Parts 100 to 177. Revised as of Oct. 1,
1982. Code of Federal Regulations, no. 49. [Washington]
1982. 831 p.

Transportation of spent nuclear fuel: the need for a flexible
regulatory system, by Sheila Bond Gig1io.. Boston College,
Environmental affairs law review, v. 12, no. 1, 1985.

101 p. (QC170 U.S.F.)

U.S. Dept. of Transportation. 1984 emergency response guidebook;
guidebook for hazardous materials incidents. [Washington]
1984. 150 p. (DOT-P-58003)

-—--- A guide to the Federal hazardous materials transportation
regulatory program. [Washington] January 1983. 53 p.

U.S. Dept. of Transportation. Federal Highway Administration.
Guidelines for applying criteria to designate routes for
transporting hazardous materials. [Washington] 1980. 67 p.
(FHWA-1P-80-15, implementation package)

UPDATE=OS/O1/86

CRS-20 IB76026
U.S. Dept. of Transportation and U;S. Nuclear Regulatory
Commission; Memorandum of Understanding between U.S.
Department of Transportation and U.S. Nuclear Regulatory
Commission for regulation of safety in the transportation
of radioactive materials. Signed June 8, l979. ll p.
U.S. General Accounting Office. Federal actions are needed
to improve safety and security of nuclear materials
transportation. Report to the Congress from the
Comptroller General of the United States» May 7, 1979.
[Washington] l979. 68 p. EMD-79-18
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