TOPIC 1: Regulations

Let’s understand the transportation of radioactive material.

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The Code of Federal Regulations (CFR) is a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the Federal Government. Each Code is revised at least once each calendar year. For the U.S. Department of Transportation (USDOT), their regulations are contained in Title 49.

49 CFR, Parts 100 to 185, of lists the requirements for shipping all sorts of hazardous materials, including radioactive material, within the U.S.   These regulations also apply when the radioactive material is transported on or across public roads, airspace, or navigable waters. The transportation of radioactive material within the facility or on the property of the owner does not need to follow USDOT regulations unless they cross a public road. Moving radioactive material from one end of a facility to another requires only safety of the radioactive material but does not require any labeling of containers, placarding of vehicles, or shipping papers.

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There are multiple agencies that are involved in regulating the shipping of Radioactive materials.  These include: USDOT, USNRC, USDOE, USPS, FAA, US COAST GUARD and AGREEMENT STATES.

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Since the U.S. is a major manufacturer of radioactive pharmaceuticals and devices, the U.S. must be able to meet international shipping regulations as well as USDOT shipping regulations. Therefore, the USDOT regulations have been modified to match international regulations outlined in the International Air Transport Association (IATA) regulations. This means that transporting radioactive materials solely within the U.S. is subject to the same guidelines as shipping internationally.

The Agreement States have adopted the USDOT 49 CFR regulations as a State regulation. This means that the Agreement State inspector can inspect shipments and records regarding USDOT to verify compliance and issue violations and fines, if necessary.

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USDOT Hazardous Material (HAZMAT) training is required every three years if transporting by ground and two years if shipping by air. This training is commensurate with only the hazardous materials that are being transported to and from the facility. In other words, if one has training in transporting fixed nuclear gauges, it does not authorize a shipper to transport other types of radioactive materials, such as spent nuclear fuel, nuclear pharmaceuticals, or other types of radioactive materials.

Note:  IATA has established guidelines for the shipment of radioactive material to other countries. Certain differences still exist between the IATA rules and USDOT. Check the IATA regulations before shipping overseas.

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USDOT HAZMAT regulations in USDOT 49 CFR, Subpart H describes who needs the current training to ship radioactive materials.  Key personnel, such as the site Radiation Safety Officer, personnel in the Central shipping and receiving area, persons involved in preparing the package for shipment and personnel signing shipping papers should have USDOT HAZMAT training.  These personnel should have a minimum understanding of radiation fundamentals and how to use a survey meter to understand and implement the USDOT requirements.  This type of knowledge is provided during the Authorized User training.   Not all Authorized Users at the facility need to have USDOT HAZMAT training.  The RSO is to determine who they feel needs the training.  However, if anyone is asked to assist in a shipment, they must have a valid USDOT HAZMAT training certificate before assisting.

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On public highways, there are certain regulations for the transport of radioactive material and certain USDOT requirements are eased. Licensing as a radioactive transporter may not be required. However, if transporting radioactive materials with company vehicles, it is important to check with the company risk manager as to whether current insurance is sufficient or company policies authorize it. Some policies have exclusions for transporting radioactive materials.

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General licensees cannot ship radioactive sources. They do not have the training, procedures, or authorization for correctly evaluating the proper shipping requirements of radioactive materials. In the event a General Licensee desires to dispose of their radioactive materials, they must contact the manufacturer of the device or an approved radioactive waste broker who will come on site, package, label, and ship the radioactive materials. The general licensee will then receive verification from the licensed broker or manufacturer as to the removal of these sources.  In the case where the General Licensee is a laboratory possessing limited amounts of liquid radioactive materials for in vitro studies, these materials are usually disposed of through the sewerage system according to instructions from the nuclear pharmacy.

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In order to know how your particular radioactive material is to be shipped, it is important to understand these definitions.  When shipping radioactive materials from a facility, it is the responsibility of the shipping facility to be in compliance with the USDOT HAZMAT regulations.

You can receive guidance from your supplier as to how the material are shipped to you and give you the best methods how to ship it out to other recipients or as radioactive waste.

The spectrum of shipment categories range from NOT REGULATED to heightened requirements such as truck placards and even escorted by US Marshals;

Here are the categories:

1. Not regulated for transport
2. For bulk loads of ore or a homogeneous material, the threshold is 0.002 microcuries per gram.
3. Limited Quantity excepted articles.
4. Type A Quantities (requiring White I, Yellow II or Yellow III labels).
5. Type B Quantities (Shipping package must be more robust).
6. Low Specific Activity has a wide range of radiation levels.
7. Highway Route Controlled Quantity (Such as shipping spent nuclear fuel with US Marshall escort)

Remember:  the definition of Radioactive Materials for shipment on or across the public highway has a variety of metrics that need to be understood by the shipper before classifying the shipment.

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Here is a summation of RADIOACTIVE shipment classifications:

• EXCLUSIVE USE – Requires determination of the Specific radiation levels on each package, the truck, and in the driver’s cab
• Type A/B packages require compliance with A1 & A2 values as defined in 49 CFR and have a

Transport Index. There must be labels on the package.

• Bulk loads Require an Activity / gram or total consignment exemption if either one qualifies
• Limited Quantity shipments depend on:
• Activity concentration
• If sent via US postal service the limit is 0.5 mR/hr
• If classified as Instruments or Articles, the radiation level must be below 0.5 mR/hour

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The transport of excepted quantities (which are small activity sources such as check sources) are excepted (exempted) from the requirements of shipping papers or packaging. The only requirement is the radiation level must remain less than 0.5 mR/hr for the duration of the shipment.

Check with a survey meter or the manufacturer of the radioactive materials as to whether your material qualifies.

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When shipping Excepted packages, no shipping papers are required; however, if present, it is not a violation.

The requirements include:

• <10 mR/hour at 4” from outside of inner package & <0.5 mR/hour from outside of package.
• No specification packaging.  In other words, it can be a cardboard box.
• The inner package should be marked with “Radioactive”, unless it is an instrument or articles.
• The package will require a Certification Statement:  “This package conforms to the conditions and limitations specified in 49 CFR 173.424 excepted package-instruments or articles, UN2911.”

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A package means the packaging plus its contents. The “packaging” is all of the paraphernalia used to hold the hazardous materials safe for transport. The “contents” are the hazardous materials only. For determining specific activity of the material enclosed, however, the package is not used in the calculations.

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The diamond label is a prescribed label that must be commercially purchased and adhered to the package. Typically, a label is the shape of a diamond with the points up and down, left and right; however, when placing on some surfaces that are rounded, it may be necessary to move it sideways like a square with the information being displayed at an angle. This is authorized as long as it is the only way to adhere the label to the package.

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The Transport Index, or TI, is the highest dose rate level at any point at one meter from the surface of the package. The TI is unit-less and is to be rounded up to the next highest  1/10th. For example, a TI of 0.53 would be correctly written as 0.6, which, for this example, is a YELLOW II. The proper category of the label must be determined as follows:

WHITE I: Dose rate must be < 0.5 mrem/hr at the surface and a TI = BKG

YELLOW II:    Dose rate must be between 0.5 mrem/hr and 50 mrem/hr at the surface; and a TI of < 1

For multiple packages with Yellow II labels, if the sum of the TIs exceeds 50, the vehicle must be placarded.

YELLOW III:   Dose rate must be between 50 mrem/hr to 200 mrem/hr; and a TI of < 10; and, the vehicle must be placarded.

When licensees receive TYPE A packages, they are to perform a TI verification on the package to determine compliance with USDOT.  If there is a difference greater than +/- 20% it is recommended to contact the shipper before reporting the discrepancy to the regulatory agency.

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If multiple radioactive packages are placed in a protective covering, such as an OVERPACK, it is required to place labels on both sides of the outer OVERPACK.  In other words, a new TI must be obtained on the entire OVERPACK.   But be careful … this may change the type of label due to the potential increased radiation levels from multiple radiation packages that are in the OVERPACK.

 

If the new OVERPACK transport index requires a YELLOW III due to the TI being above 1 mrem/hour and each one of the packages in the OVERPACK are YELLOW IIs (less than one mrem/hour), it is advisable to use two OVERPACKS and split the packages on the pallet.  This will reduce the radiation level so the OVERPACK can be classified as a YELLOW II only.  This would prevent the need to PLACARD the vehicle.

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When shipping Type A packages, the OVERPACK is an optional task.  If it is removed during a shipment accident, it does not compromise the radiation levels of the shipment.

When an OVERPACK is used, the MARKING of “OVERPACK” or “INNER PACKAGES COMPLY” must me marked on the OVERPACK.

The shipping labels of White I, Yellow II or Yellow III are to be used on an OVERPACK for Type A packages.  When the Type A packages (in the OVERPACK) are properly labelled, if the overpack is accidently removed, it is not a compliance issue.  However, the labels need to adhere to the package during the shipment.

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The radioactive materials placard is a USDOT requirement anytime transporting Yellow III material or If the total of the Yellow Iis exceed a TI of 50.

The placards are to be on all four sides of the vehicle on a flat surface and facing outward. If a contract carrier is used, they need to be notified when placarding is required. Shipping with placarded company vehicles could potentially be more costly, may required additional insurance and subject the company to more procedures or regulations.  Recommend checking with your risk manager before proceeding with this option.

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The Bill of Lading (BOL) meets the most basic requirements for a licensed user of radioactive material to transport their own material on public highways. USDOT can inspect personal vehicles and will want to see some form of documentation if they see the radioactive material. At a minimum, the Bill of Lading will contain:

Consignee (where the shipment is going) (address & phone #)

Shipper (address & phone #)

Radioactive Material

Radioactivity (in becquerels with curies in parenthesis)

USDOT ID Number (found at 49 CFR 172.101)

24-hour emergency phone

• The 24-hour emergency phone number must be answerable by a knowledgeable person & cannot go to voicemail.

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If shipping a reportable quantity, A SHIPPER’s DECLARATION for Dangerous Goods is required.  To determine whether your shipment is a reportable quantity, refer to the USDOT HAZMAT regulations 49 CFR 172.101 Appendix A for a List of Hazardous Substances and Reportable Quantities.  You can also check with the vendor who shipped the radioactive materials to you.

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If shipping radioactive materials that are prone to have contamination during usage, such as liquids or powders, contamination control is to be verified before shipping.

Shipping materials are to be:

• Packaged in containers
• Swipes must be taken on the outside of each package
• Results must be:

less than 24 dpm/cm2 of alpha emitting materials; or

less than 240 dpm/cm2 of beta/gamma emitting materials.

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Here are some typical USDOT violations:

• Leaking packages
• Contaminated packages
• Radiation levels exceeding classification
• Load not secure in the vehicle
• Labels/markings incorrect or missing
• Shipping papers are incomplete

Typical fines:  $3,000-$8,000 per incidence

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When RECEIVING RADIOACTIVE MATERIALS AT YOUR FACILITY:

1. Note that the package is undamaged
2. If damaged, contact the RSO immediately and do not let the transporter leave the premises.
3. Take a picture of the damaged package.
4. Survey the package to ensure any shielded source has not escaped its container.
5. Isolate the package until the RSO arrives.

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WHAT TO DO AS THE RSO:

• Confirm the USDOT classification of your radioactive materials
• Discuss with your shipper/vendor as to the proper method of shipping & receiving radioactive materials
• Submit procedures to your regulatory agency as to your methods used to receive and ship radioactive materials. This may have already been done with your radiation protection manual as part of the facility’s radioactive materials license.
• Obtain site specific and hazard specific training for all necessary personnel on shipping and receiving your radioactive materials.