Appendix C - Training Table 2


				 TABLE II
		      Minimum Training Requirements
	      for Personnel Engaged at EM-40 RCRA TSD Sites


   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 employees directly     29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
involved in TSD facilities   and (ii) require a minimum     (p)(7)(i) and (ii),
operations on a daily or     of 24 hours Initial Health     DOE 1993b,
occasional basis, i.e.,      and Safety Training, or        DOE 1993c,
supervising contractor       equivalent instruction, for    DOE 1994, and
employees and evaluating     current employees.  However,   NIEHS 1993
program outcome.             EM-40 adoption of OSHA
                             standards requires a minimum
                             of 40 hours Initial Health
                             and Safety Training and 24
                             hours supervised field
                             experience.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Contractor or          29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
Subcontractor TSD Facility   and (ii) require a minimum     (p)(7)(i) and (ii),
Manager (FM) responsible     of 24 hours Initial Health     DOE 1993b,
for operations such as       and Safety Training, or        DOE 1993c,
handling drums or            equivalent instruction, for    DOE 1994, and
containers.  The TSD FM is   current employees.  However,   NIEHS 1993
also responsible for         EM-40 adoption of OSHA
supervising TSD employees    standards requires a minimum
and has authority to         of 40 hours Initial Health
direct response              and Safety Training and 24
operations.                  hours supervised field
                             experience.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Contractor or          29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
Subcontractor Facility       and (ii) require a minimum     (p)(7)(i) and (ii),
Safety and                   of 24 hours Initial Health     DOE 1993b,
Health Officer (FSHO)        and Safety Training, or        DOE 1993c,
responsible for              equivalent instruction, for    DOE 1994, and
implementation of all        current employees.  However,   NIEHS 1993
aspects of Safety and        EM-40 adoption of OSHA
Health Plan at the           standards requires a minimum
facility.  The FSHO is       of 40 hours Initial Health
also responsible for         and Safety Training and 24
implementing the Emergency   hours supervised field
Response Plan whenever       experience.
warranted at the facility.
FSHO has authority to
direct response operations
and reports to upper level
management.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Contractor or          29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
Subcontractor Designated     and (ii) require a minimum     (p)(7)(i) and (ii),
Emergency Response Person    of 24 hours Initial Health     DOE 1993b,
(DERP) certified in first    and Safety Training, or        DOE 1993c,
aid/CPR by the American      equivalent instruction, for    DOE 1994, and
Red Cross, or equivalent.    current employees.  However,   NIEHS 1993
The DERP is assigned to      EM-40 adoption of OSHA
the facility crew to         standards requires a minimum
provide first aid and CPR    of 40 hours Initial Health
services and is on the       and Safety Training and 24
facility whenever            hours supervised field
employees are working at     experience.
the facility.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Contractor or          29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
Subcontractor Facility       and (ii) require a minimum     (p)(7)(i) and (ii),
Command Post Supervisor or   of 24 hours Initial Health     DOE 1993b,
Facility Emergency           and Safety Training, or        DOE 1993c,
Coordinator (FEC)            equivalent instruction, for    DOE 1994, and
responsible for              current employees.  However,   NIEHS 1993
implementing the emergency   EM-40 adoption of OSHA
plan, whenever conditions    standards requires a minimum
at the facility warrant      of 40 hours Initial Health
such action.  The FEC who    and Safety Training and 24
may be the same person as    hours supervised field
the TSD Facility Manager     experience.
conducts activities such
as evacuation, emergency
transport of facility
personnel, as necessary,
and notifies emergency
response units and
appropriate management
staff.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Contractor or          29 CFR 1910.120(p)(7)(i)       29 CFR 1910.120
Subcontractor facility       and (ii) require a minimum     (p)(7)(i) and (ii),
operators engaged in         of 24 hours Initial Health     DOE 1993b,
activities such as           and Safety Training, or        DOE 1993c,
handling drums or            equivalent instruction, for    DOE 1994, and
containers, or operation     current employees.  However,   NIEHS 1993
of a treatment unit such     EM-40 adoption of OSHA
as an incinerator or         standards requires a minimum
activated carbon             of 40 hours Initial Health
adsorption system.           and Safety Training and 24
                             hours supervised field
                             experience.

                             EM-40 requires a minimum       DOE 1993b,
                             of 8 hours Supervisor          DOE 1993c,
                             Training.                      DOE 1994 and
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120(p),
                             standards requires a minimum   DOE 1991, 
                             of Facility-Specific           DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993


                             EM-40 adoption of OSHA         29 CFR 1910.120
                             standards requires a minimum   (p)(7)(i),
                             of 8 hours Annual Refresher    DOE 1993b,
                             Training.                      DOE 1993c,
                                                            DOE 1994 and 
                                                            NIEHS 1993

                                                            
                             Emergency Response and         29 CFR 1910.120
                             Periodic Rehearsal Training.   (p)(8)(iv),
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993

                             Hazard Communication           29 CFR 1910.120,
                             Training                       29 CFR 1926.59


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



   Operational Personnel       Training Requirement           Reference(s)
----------------------------------------------------------------------------

EM-40 Visitors/Non-Workers   OSHA requires no minimum       DOE 1993b,
who enter the facility.      training for                   DOE 1993c,
PPE should be issued to      Visitors/Non-Workers who       DOE 1994, and
all Visitors/Non-Workers,    enter the facility.            NIEHS 1993
and they should be           However, EM-40 requires a
instructed on its proper     minimum of 40 hours Initial
use.  All EM-40 employees    Health and Safety Training
and offsite personnel not    and 24 hours supervised
directly involved with TSD   field experience.*
facility operations, are
Visitors/Non-Workers.

                             Facility-Specific Training     DOE 1991,
                                                            DOE 1993b,
                                                            DOE 1993c,
                                                            DOE 1994, and
                                                            NIEHS 1993


                             8 hours Annual Refresher       DOE 1993b,
                             Training.*                     DOE 1993c,
                                                            DOE 1994, and
                                                            NIEHS 1993


                             Radiological Worker Training,  DOE Notice 5480.6,
                             if applicable.  For details,   DOE 1992,
                             see DOE Radiological Control   DOE 1993b,
                             Manual (DOE/EH-0256T).         DOE 1993c,
                                                            DOE 1994 and
                                                            NIEHS 1993



    *  This training is required for all visitors/nonworkers who enter an
       exclusion/decontamination zone or other areas where Level A, B, or C
       PPE is required.  This training is not required for
       visitors/non-workers who only enter areas where either Level D or no
       PPE is required.  See memo from Mr. Pat Whitfield, EM-40 to EM-40
       Offices, dated February 2, 1994.