Shipment Receipt of Radioactive Materials - PowerPoint by broverya84

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									Shipment & Receipt of
Radioactive Materials

           By
       Mike Zittle
     Health Physicist
         Why are You Here?
   It’s REQUIRED!
     DOT Training Requirements
   Subpart H - Training (49 CFR 172.700)
   Requirements - 49 CFR 172.704(a)
    1 General Awareness / Familiarization - [THIS]
       • To identify hazardous materials
    2 Function - Specific Training
       • Applicable to functions performed
          – i.e. Generator Shipments - revised procedure
    3 Safety Training - HAZWOPER covers this
       • Emergency Response, etc.
    – Additional DOT Training Requirements MAY
      apply - Modal Specific Training
General Awareness / Familiarization
        49 CFR 172.704(a)
     Employee must be able to:
      – recognize and identify hazardous material
      – those materials containing radioactivity that are
        regulated by DOT as HAZMAT
     What is radioactivity and radiation?
      – How does radiation interact?
      – What are sources of radiation exposure?
      – What are the health risks?
     What are radiation protection regulations?
     Function - Specific Training
         49 CFR 172.704(a)
   Functions include:
    – Shipping, Carrying, Receiving, and Preparing a
      package or container
   Training is to include:
    – Shipping Classification, Packaging, Labeling,
      Marking, Preparation of Shipping Papers
    – Surveying and Record Keeping
    – Other information, as necessary
             Safety Training
           49 CFR 172.704(a)
   Emergency Response information
   Measures to protect the employee
   Methods and procedures to prevent
    accidents
   HAZWOPER Training usually satisfies this
    requirement
    Responsibility for Training and
      Testing - 49 CFR 172.702
   HAZMAT Employer is responsible for
    training
   HAZMAT Employees MAY NOT perform
    functions without training
   Training may be provided by any source
   Employees MUST be tested by appropriate
    means
     DOT Training Requirements
   172.704(b) - OSHA or EPA Training
    – Training to comply with Hazard
      Communication (HazCom) requirements of 29
      CFR 1910.120 or 49 CFR 311.1 MAY satisfy
      the requirements of 49 CFR 172.704(a)
     DOT Training Requirements
   172.704(c) - Initial and Recurrent Training
    – Employee may perform job functions
       • If supervised by a HAZMAT trained employee
       • Training is completed within 90 days
   Retraining required every 3 years
   Relevant Training
    – Previous employer training may satisfy if you
      have documentation
   The HAZMAT Employer is responsible for
    compliance with DOT regulations
     DOT Training Requirements
   172.704(d) Recordkeeping
    – Employer shall keep records of training within
      the last 3 years
    – Records for each employee shall be kept until
      90 days after separation
    – Include Employee’s name, training date,
      training materials (or material location), name
      and address of trainer, and certification of
      training
         HAZMAT Certification
   Since it is the responsibility of the employer
    to assure that their employees have been
    trained and tested, only the employer may
    certify that the employee has been
    appropriately trained and tested
The Goal of this Training Class
    What is the Goal of This Class?
   General Awareness / Familiarization
    – BROAD overview of DOT regulations for
      transporting hazardous materials
       • Specifically Radioactive Materials
   Function - Specific Training
    – Revised Generator Shipment Procedure
    – Hands on Generator Packaging Exercise
       • separate training session
                  Outline
   Applicability
   NRC Regulations
   DOT Regulations
   Training Regulations
   Package Receiving / Inspection
   Safety Training / Emergency Response
Applicability of DOT
HazMat Regulations
     Applicability of Hazardous
    Materials (HazMat) Regulations
   49 CFR 171.1 - applies to transportation in
    commerce
     – by Rail, Aircraft, Vessel, or Highway
     – Interstate Carriers
     – Intrastate Carriers
   49 CFR 171.1 - also applies to preparation
    of packages or containers for use in
    transportation - making and certifying
    packages
NRC Regulations
             NRC Regulations
   Packaging and Transportation of
    Radioactive Material [10 CFR 71]
    – Requirements for packaging, preparation, and
      transportation of licensed material
   Packaging and Transportation of
    Radioactive Material [10 CFR 71.5]
    – Simply says “Follow DOT Regulations”
       • 49 CFR 170-189
DOT Regulations
            DOT Regulations
            49 CFR 170-189
   DOT Packaging, Marking, and Labeling
   Placarding, Accident Reporting
   Shipping Papers, Emergency Information
   Training, Shipper / Carrier Registration

   If DOT Regs are not applicable to a
    shipment of Licensed RAM, you must still
    follow DOT Regs as if they were applicable
    – 10 CFR 71.5
       Exemption for Low-Level
       Materials [10 CFR 71.10]
   Regulations do not apply to materials with a
    specific activity < / = 70 Bq/g (0.002 μCi/g)
   If DOT Regs are not applicable to a
    shipment of Licensed RAM, you must still
    follow DOT Regs as if they were
    applicable.
     Steps to Understanding DOT
              Regulations
   Classification
   Packaging
   Labeling
   Radiation Limits
   Marking
   Shipping Papers
   Placarding
   Conveyance
             DOT Regulations
   DOT Regs are based on IAEA
    – protection of the public by good packaging
   NRC Regs are based on DOT Regs
   Agreement States are based on NRC Regs
   Air Transport Regs are based on IATA
   IATA Regs are based on ICAO

   Bottom line: There are Many Regulations!
             DOT Regulations

   DO NOT Apply to:

    – RAM in a medical device implanted into a
      human or animal
    – RAM that has been injected into, ingested, or
      placed into and are still in humans or live
      animals
DOT Classification
       Classification of RAM -
Different Levels of DOT Requirements
        Exemptions
        Excepted (Limited) Quantities
        Special / Normal Form
        Type A Quantities
        Type B Quantities
        LSA, SCO, Empty
             DOT Classification
   Class 7, Radioactive Materials
    – Other DOT Classes - 49 CFR 173.2
    – Refer to handout of DOT Classes
   Class 7 ALWAYS takes precedence
    EXCEPT for:
    –   Class 1 (Explosives)
    –   Class 5.2 (Organic Peroxides)
    –   Class 4.1 (Wetted Explosives)
    –   Limited Quantities of RAM
                Classification
   Defined as a hazardous material by DOT as
    radioactive materials with concentrations
    greater than 70 Bq/g
    – (0.002 μCi/g or 2 nCi/g or 4200 dpm/g)
              DOT Exemptions
   < / = 70 Bq/g or 0.002 uCi/g
    – NOT considered a hazardous material by DOT
   Specific Wastes - 10 CFR 20.2005
    – LSC Media / Cocktail and Animal Tissue
       • containing less than 0.05 μCi/g H-3 or C-14


   Either one of these conditions - EXEMPT
    from DOT Rules (except for aircraft)
    Classification as Special Form
   49 CFR 173.403 and 173.469
   Solid piece or sealed capsule
    – Can only be opened by destruction
   Must be certified by a competent authority
   ALL Special Form materials are classified
    as Sealed Sources by the NRC, but
   Not all Sealed Sources are Special Form
    materials
    Classification as Normal Form
   49 CFR 173.403
   Anything which is does not qualify as
    Special Form
   Can be solid, liquid, or gaseous
              Classification
             A1/A2 Quantities
   A1 Quantity - (usually greater than A2)
    – Maximum activity of Special Form material in
      a Type A Package
   A2 Quantity
    – Maximum activity of Normal Form material in
      a Type A Package
   No Nuclides are assigned more than 1080
    Ci, although some are “unlimited”
    Classification - Other Quantities
   Type B Quantity
     – Special Form - Exceeds A1 Quantity
     – Normal Form - Exceeds A2 Quantity
   Highway Route Controlled Quantity
    (HRCQ)
     – Special Form - Exceeds 3000 A1 Quantity
     – Normal Form - Exceeds 3000 A2 Quantity OR
     – Exceeds 1000 TBq (27,000 Ci), whichever is
       least
         Special Classifications
   Excepted Quantities
   Empty
   LSA
   SCO
    Excepted (Limited) Quantities /
           Empty Packages
   Greater than 70 Bq/g (0.002 µCi/g)
   “Excepted” from specification packaging,
    marking, labeling, shipping paper, and
    certification requirements if not hazardous
    waste
   This material is NOT EXEMPT from DOT
    regs
                LSA and SCO
   LSA - Low Specific Activity
    – Generally pertains to bulk materials like ores,
      waste, and activated items
   SCO - Surface Contaminated Object
    – Generally for power plant items
    – Occasionally found on research instruments
                Classification
   LSA (49 CFR 173.403)
    – LSA-I, LSA-II, LSA-III
   SCO (49 CFR 173.403)
    – Object which itself is not radioactive, but has
      RAM on any of its surfaces
    – SCO-I - non-fixed and fixed contamination on
      accessible and inaccessible areas
    – SCO-II - (MORE) non-fixed and fixed
      contamination on accessible and inaccessible
      areas than SCO-I
    – Averaged over 300 cm2, or over entire surface
      if less than 300 cm2
         Review of Classifications
   Exempt - not considered radioactive (for DOT
    purposes) - < 2 nCi/g
   Excepted / Empty - some rules apply, small
    amounts of activity
   Type A - More Activity than Excepted
   Type B / HRCQ - More Activity than Type A
   LSA / SCO - special rules, special material
Transportation Activity Spectrum
   Not          Limited      Type A        Type B       Highway
   Regulated in Quantities   Quantities,   Quantities   Route
   Transport    and          LSA, SCO                   Controlled
                Excepted                                Quantity
                Articles



            Excepted     Type A        Type B       Type B
                Packaging    Packaging     Packaging    Packaging


   < 70 Bq/g    10-3 A1 –    Up to A1 or                3000 A1 or
   (< 0.002     Solids       A2                         3000 A2 or
   Ci/g)       10-3 A2 –                               27,000 Ci
   (<2 nCi/g)   Solids                                  (Whichever
                10-4 A2 –                               is the least)
                Liquids
General Requirements
     Radiation Level Limitations
         (49 CFR 173.441)
   Generally Dose Rates at package surfaces
    must not exceed 200 mrem/hr
   Transport Index (TI) may not exceed 10
   If these levels are exceeded, package must
    be shipped “Exclusive Use”
   Packages exceeding 200 mrem/hr at surface
    and TI > 10 may not be shipped by aircraft
                 Exclusive Use
   Also known as “Sole Use” or “Full Load”
   Radiation Limits
    – Surface Levels up to 1 rem/hr
    – Outer Surface of Vehicle up to 200 mrem/hr
    – 10 mrem/hr at 2 meters from the outer surface
      of the vehicle
    – 2 mrem/hr in normally occupied spaces
       • i.e. Truck Cab
       • Unless operating under provisions of a Federally or
         State regulated Radiation Protection Program
       • Unless driver is badged with dosimeter(s)
           Contamination Control
            49 CFR 173.443(a)
   Level of non-fixed (removable) surface
    contamination must be ALARA
   May not exceed limits specified in Table 11
   Must wipe at least 300 cm2
    –   Use absorbent material
    –   Apply moderate pressure
    –   Measure activity on swipe
    –   Must take swipes in areas most likely to have
        contamination
  Contamination Limits - Table 11
        (49 CFR 173.443)
                              Maximum Contamination Permitted
   Contaminant
                   Bq / cm2    Ci / cm2          dpm / cm2     dpm / 300 cm2

Beta / Gamma and
Low Toxicity
Alpha Emitters
                    0.4          10-5                22            6600
All other Alpha
Emitters            0.04         10-6               2.2             660




      Exclusive Use Shipments have many more
      Contamination Control Requirements
    Quality Control Requirements
          (49 CFR 173.475)
   Before shipping Class 7 Radioactive
    material, the offeror must ensure
    – Packaging is proper
    – Packaging is in unimpaired condition
    – Closure devices are installed, secured and free
      of defects
    – Neutron absorbers, if required, are present
    – Instructions for preparing package have been
      followed
    Quality Control Requirements
   The offeror must also ensure
    – Any closure valves, or other openings are
      closed and sealed
    – Packages of liquids for air transport have been
      tested under appropriate atmospheric conditions
    – The internal pressure will not exceed design
      criteria
    – External radiation and contamination levels are
      within acceptable limits
Packages
              Packages
        General Design Criteria
   49 CFR 173.410
   Package can withstand normal transport,
    acceleration, vibration, and resonance
   Package materials and components are
    physically and chemically compatible
   Many more criteria, etc.
             Type A Packages
   Packaging that, together with its contents,
    – May be used to ship up to the A1 Limit if
      Special Form
    – May be used to ship up to the A2 Limit if
      Normal Form
    – Table of A1 and A2 values (49 CFR 173.435)
   Will retain integrity and shielding during
    normal transportation
   Must pass tests specified in §173.465/466
     Packaging - Type A Package
       Tests (49 CFR 173.465)
   Water Spray Test equivalent to rainfall of 5
    cm/hr
   Free Drop Test from various distances
    based on mass
    – Corner / Rim Drops
   Stacking Test - 24 hour load of 5X the mass
    or 1.9 lbs./in2, whichever is greater
   Penetration Test using 3.2 cm bar of 6 kg
    dropped from 1 meter
    Packaging a Type A Quantity of
         Radioactive Material
   49 CFR 173.415
   May use DOT Specification 7A container
     – §178.350
     – Certification of test results for 7A Packaging
       must be kept on file for one year after shipment
             Packaging
       Type B, Fissile Materials
   Authorized Type B Packages
    – 49 CFR 173.416
   Authorized fissile material packages
    – 49 CFR 173.417
   Usually Not Applicable at UCLA
Labeling
              Labeling
     Surface Radiation Level and
         Transport Index (TI)
   49 CFR 172.403
   TI - Maximum dose rate in mrem/hr at 1
    meter from package surface rounded to the
    nearest tenth
   If dose rate is less than 0.05 mrem/hr, TI is
    defined to be 0
   Cannot be greater than 10 - except for
    Exclusive Use Shipments
                     Labeling
                Surface Radiation   Transport Index
   Label                                              Label
                 Level (mrem/hr)       (1 Meter)


   White I          Up to 0.5            N/A



  Yellow II        >0.5 – 50           >0 – 1.0



 Yellow III        >50 – 200           >1 – 10


 Yellow III
                  >200 – 1000            >10
Exclusive Use
         Labeling - Information
   Contents - list of radionuclides
    – select authorized symbols - (49 CFR 173.435)
    – H-3, C-14, I-125, P-32, etc.
   Activity - SI Units Required
       • (Bq, MBq, GBq)
    – Ci units are optional in parentheses
    – 1 Ci = 3.7 x 1010 Bq or 37 GBq
   TI - Yellow II and Yellow III only
    – 49 CFR 172.403 (g)(3)
     Labeling a Type A Shipment
   Affix 2 White I, Yellow II or II labels as
    appropriate - 49 CFR 172.403
    – On opposite sides of the package - not bottom
    – Near marked proper shipping name
   Cargo Aircraft Only - Label
    – If package is authorized for cargo aircraft only
       • 49 CFR 172.402(c)
Marking
     Marking a Type A Shipment
   Package marked with proper shipping name
    and identification number
       • 49 CFR 172.301(a)
    – Shipping names in table in 49 CFR 172.101
       • i.e. Radioactive Material, n.o.s., 7, UN 2982
   Package marked with weight - if greater
    than 50 kg (110 lbs.)
   International Shipments must bear “USA”
    marking
     Marking a Type A Shipment
   Package marked as “Type A” in letters at
    least 13 mm high
   The letters “RQ” for Reportable Quantity
    must be marked on the package along with
    the shipping name if:
    – Quantities of RAM are at or above the limits
      found in 172.101 Appendix A are in the
      package
   Name and Address of Consignor (Shipper)
    or Consignee (Receiver) on the package
Shipping Papers
          Shipping Papers for a
           Type A Shipment
   Proper shipping name, hazard class, UN
    number
   Name of each radionuclide as listed in 49
    CFR 173.435
    – 49 CFR 172.203 (d)(1) and (2)
    – see 49 CFR 173.433 (f) for mixtures
   Description of physical and chemical form
    – 49 CFR 172.203 (d)(3)
          Shipping Papers for a
           Type A Shipment
   “RQ” must appear also either before of after
    the basic description, if applicable
    – RQ, Radioactive material, n.o.s., 7, UN 2982
      I-125    10 mCi     H-3        100 Ci
      I-129    1 mCi      C-14       10 Ci
      I-131    10 mCi     S-35        1 Ci
      P-32     100 mCi    Co-60      10 Ci
      Proper Shipping Name, Hazard
       Class, ID Number: Domestic
    49 CFR 172.101 - Hazardous Materials Table
   Radioactive Material, excepted packages - articles
    manufactured from natural or depleted uranium or
    natural thorium, 7, UN2910
   Radioactive Material, excepted package - instruments
    or articles, 7, UN2910
   Radioactive material, fissile, n.o.s., 7, UN2918
   Radioactive Material, LSA, n.o.s., 7, UN2912
   Radioactive Material, special form, n.o.s., 7, UN2974
       Proper Shipping Name, Hazard
             Class, ID Number:
         International / Air (NEW)
   Radioactive Material, excepted packages - articles
    manufactured from natural or depleted uranium or
    natural thorium, 7, UN2909
   Radioactive Material, excepted package - instruments
    or articles, 7, UN2911
   Radioactive material, Type A Package, fissile, non
    special form, 7, UN3327
   Radioactive Material, low specific activity (LSA-I),
    non-fissile or fissile excepted, 7, UN2912
   Radioactive Material, low specific activity (LSA-II),
    non-fissile or fissile excepted, 7, UN3321
    Shipping Papers for a Type A
             Shipment
   Activity in SI units, Bq or GBq
   Category of label applied to shipment
    – i.e. RADIOACTIVE WHITE-I
   Transport Index (if applicable)
    – 49 CFR 172.203 (d)(6)
   “Cargo Aircraft Only” on shipping paper, if
    on package
            Shipping Papers for a
             Type A Shipment
   Shipper’s Certification - 49 CFR 172.204(a)
    – “This is to certify that the above-named materials
      are properly classified, described, packaged,
      marked and labeled, and are in proper condition
      for transportation according to the applicable
      regulations of the Department of Transportation.”
   Signature - 49 CFR 172.204 (d)
    – must be legibly signed by principle, officer,
      partner, employee of shipper or his agent
    – may be legibly signed by mechanical means
             Shipping Papers for a
              Type A Shipment
   Different rules apply for fissile materials or
    Highway Route Controlled Quantities
    – 29 CFR 173.203
   For passenger aircraft - 49 CFR 173.204(c)(4)
    – Requires printed certification stating that:
       “This shipment contains radioactive material
      intended for use in, or incident to, research, or
      medical diagnosis or treatment.”
Emergency Response
   Information
         Emergency Response
     Information - 49 CFR 172.600
   Applies to persons shipping RAM
   Applies as long as the RAM is in transit
   Information must be available immediately
   Emergency Response Information
    – Information used to mitigate an accident
    – Description and technical name of RAM
    – Hazards to health, risk of fire, precautions in
      event of an accident, methods for handling fires,
      methods for handling spills, first aid measures
    – NAERG Pages
          Emergency Response
             Information
   Form of information
    – Printed in legible English
    – Available for use away from the RAM package
   Information is presented on:
    – A shipping paper
    – In another document
       • MSDS, NAERG, etc.
          Emergency Response
             Information
   Maintenance of information
    – Carriers
       • information must be immediately accessible to
         pilots, drivers, etc.
       • Driver’s (are supposed) to carry shipping papers and
         emergency response information in the driver’s
         compartment - NOT IN THE BACK OF THE
         TRUCK WITH THE PACKAGE
    – Facility Operators
       • Must be immediately available wherever RAM is
         received, stored, or handled during transit
              Emergency Response
                 Information
   Emergency Response Phone Number
   Shipper must provide a 24-hour number
    – For use in event of an emergency
    – Number must be monitored as long as RAM is in
      transit
    – Number is of person with specific knowledge of
      RAM in shipment or with access to someone with
      specific knowledge
    – Number is of the shipper or otherwise responsible
    – The number goes on the shipping paper
Placarding
                 Placarding
              49 CFR 172.500
   Placards go on vehicles
    – No activity written on it
    – No nuclide information on it
   Placards are required for
    – LSA, SCO, Exclusive Use Shipments
    – Yellow III Shipments, and Exclusive Use
    – Highway Route Controlled Quantity
Special Classifications
Excepted Activity Limits - Table 7
        49 CFR 173.425
                         Limits for Each                      Limited Quantity
 Nature of Contents      Instrument or Article Package Limits Package Limits
 Solid: Special Form     10-2 A1               A1             10-3 A1
 Solid: Normal Form      10-2 A2              A2              10-3 A2
 Tritiated Water
 <0.0037 TBq/L
 (0.1 Ci/L)                                                   37 TBq (1000 Ci)
 0.0037 TBq/L -
 0.037 TBq/L
 (0.1 Ci/L - 1.0 Ci/L)                                        3.7 TBq (100 Ci)
 >0.37 TBq/L
 (1.0 Ci/L)                                                   0.037 TBq (1.0 Ci)
 Other Liquids           10-3 A2              10-1 A2         10-4 A2
 Gases: Tritium          2x10-2 A2            2x10-1 A2       2x10-2 A2
 Gases: Special Form 10-3 A1                  10-2 A1         10-3 A1
 Gases: Other Form       10-3 A2              10-2 A2         10-3 A2
      Requirements for Excepted
      Package - Limited Quantity
   Table 7 - Activity Limits for Limited
    Quantities, Instruments, and Articles
   Activity Limits < Table 7 - 49 CFR 173.425
   Package meets general design requirements
    - 49 CFR 173.410
   Surface Radiation Levels < 0.5 mrem/hr
   Non-fixed contamination on surface meets
    limits specified in 29 CFR 173.443(a)
   Outside of inner packaging or outer
    packaging says “Radioactive”
      Requirements for Excepted
      Package - Limited Quantity
   Must also follow requirements specified in
    49 CFR 173.422
   If not a hazardous substance or hazardous
    waste or reportable quantity, then you do
    not need to follow shipping paper
    description for RAM or passenger aircraft
    certification for research or medical use
    materials
     Excepted Package - Limited
          Quantity Notice
   Notice to include name of consignor or
    consignee and the statement:
    “This package conforms to the conditions and
      limitations specified in 49 CFR 173.421 for
      radioactive material, excepted package - limited
      quantity of material, UN 2910.”
   Notice must be in or on package, with
    packing list, or forwarded with the package
Excepted Package - Instrument or
   Article - 49 CFR 173.424
   Same requirements as for LQ Materials
   Dose rate from unshielded item must be
    < 10 mrem/hr at 10 cm
   If shipped Exclusive Use, does rate from the
    surface of the package must be < 2 mrem/hr
Excepted Package - Instrument or
            Article
   Include a notice containing the following
    statement:
     “This package conforms to the conditions
    and limitations specified in 49 CFR 173.421
    for radioactive material, excepted package -
    instruments or articles, UN 2910.”
   Do not exceed activity limits per article and
    total limits per package as specified in
    Table 7 - 49 CFR 173.425
 Activity limits for Limited
Quantity Materials Packages,
  Other Liquids - 10-4 A2
                        -4
Materials   A2 (Ci)   10 A2 (mCi)
  H-3        1080         108
 C-14        54.1        5.41
 S-35        54.1        5.41
 P-32        8.11        .811
 Cr-51        811        81.1
 I-125       54.1        5.41
 Activity limits for Limited
Quantity Materials Packages,
Solids, Normal Form - 10-3 A2

Materials   A2 (Ci)   10-3 A2 (mCi)
Cs-137        13.5         13.5
 Co-60        10.8         10.8
Am-241      .00541       .00541
          Limited Quantity
      Multiple Hazard Shipments
   If L.Q. RAM meets definition of another
    hazard class
    – Must be classed for the additional hazard
    – Packaged in accordance with L.Q. RAM
      requirements
    – Do not need to include the required notice or
      follow other shipping paper requirements if the
      entry “Limited Quantity of Radioactive
      Material” appears on the shipping paper with
      basic description
        Empty Class 7 Materials
   Excepted from shipping paper, certification,
    and marking requirements when
   Packaging is emptied of contents as much
    as practicable
   Dose rate at package surface <0.5 mrem / hr
   Outside surface contamination limits met
    – 49 CFR 173.443(a)
   Package contains <15 g U-235
        Empty Class 7 Materials
   Package unimpaired and securely closed
   Internal contamination <100 times limits in
    49 CFR 173.443(a)
    – 2200 dpm/cm2 beta/gamma, low toxicity alpha
      emitters
    – 220 dpm/cm2 other alpha emitters
   Labels removed or defaced and “Empty”
    label applied
   Required notice included
    – 49 CFR 173.422(a)(4)
      Empty Package Statements
   This package conforms to the conditions
    and limitations specified in 49 CFR 173.421
    for radioactive material, excepted package-
    limited quantity of material, UN2910.
   This package conforms to the conditions
    and limitations specified in 49 CFR 173.424
    for radioactive material, excepted package-
    instruments or articles, UN2910.
          Empty Package Statements
   This package conforms to the conditions and
    limitations specified in 49 CFR 173.426 for
    radioactive material, excepted package-articles
    manufactured from natural or depleted uranium,
    or natural thorium, UN2910.
   This package conforms to the conditions and
    limitations specified in 49 CFR 173.428 for
    radioactive material, excepted package-
    empty package, UN2910.
Requirements for LSA and SCO
       49 CFR 173.427
   Additional requirements for LSA and SCO
    –   External Dose Rate Limitations
    –   Activity Limits
    –   Contamination Limits
    –   Must use Industrial Packaging (IP), etc.
    –   Exclusive Use loading and Transporting
        Requirements
Conveyance
            Passenger Aircraft
   Radioactive Material on passenger aircraft
    must be for research or medical use
    – 49 CFR 173.448(f)
   Transport index must be <3.0 if passengers
    are on board
   Type B Packages are not allowed on
    passenger aircraft
   Separation Distances apply
   Cargo Aircraft have fewer restrictions
Carriage by Public Highway
     Carriage by Public Highway
   Packages labeled White I, Yellow II, or
    Yellow III cannot be carried in
    compartments occupied by passengers
    (except couriers) - 49 CFR 173.448(c)
   General Information
    – Carriers are responsible for complying with
      regs and for training of HAZMAT employees
    – no unnecessary delays in the movement of
      hazardous materials
    – Carrier may not accept forbidden materials
              Driver Training
              49 CFR 177.816
   Drivers must be trained
    – Requirements of 49 CFR 390-397
    – Pre-trip safety inspections
    – Vehicles controls, equipment
    – Operation of vehicle
    – Maneuvering tunnels, bridges, RR crossings
    – Vehicle routing, attendance, smoking, incident
      reporting
    – Loading / unloading of HAZMAT
              Shipping Papers
              49 CFR 177.817
   Carrier may not accept HAZMAT without
    shipping papers (unless excepted)
   Must be certified by the shipper
   Shipping paper must be readily available
    – within reach when driving or in door
      compartment
    – on seat or in door compartment when not at
      vehicle controls
   It is prudent to hand the shipping papers to
    the driver separate from the package
      Contamination of Vehicles
          49 CFR 177.843
   Vehicles used for exclusive use shipments
    must be surveyed after use
    – Interior does rates may not exceed 0.5 mrem/hr
    – Contamination levels must meet limits in
       • 49 CFR 173.443(a)
   For vehicles used solely for RAM, vehicles
    must be stenciled “For Radioactive
    Materials Use Only” and interior dose rates
    may not exceed 10 mrem/hr
    New International Regulations
   Radioactive Material is no longer defined as
    70 Bq/g
    – concentration limit set for each nuclide
    – total activity limit for an exempt consignment
   Additional Shipping Names
   Etc.
            US Postal Service
   No air transportation by US Postal Service
   No labeled packages
   Limited Quantities / Excepted Articles
    accepted if
    – 1/10 of DOT Limited Quantities
   US Postal Service will RARELY (if ever)
    be used to transport RAM to and from
    UCLA
   Receiving and Opening
Radioactive Material Packages
           Receiving Packages
   When receiving packages containing
    materials in excess of Type A Quantity:
    – make arrangements to receive package when
      offered for delivery
    – When notified it’s at the carrier’s terminal
    – Monitor labeled package for external
      contamination (except if gas or special form)
    – Monitor labeled package for external radiation
      levels - White-I, Yellow-II, Yellow-III
             Receiving Packages
   When receiving packages containing
    materials not greater than Type A Quantity:
    – monitor labeled package for external
      contamination (except gas or special form)
   When receiving damaged packages:
    – monitor ALL packages for external
      contamination
    – monitor ALL packages for external radiation
      levels
   Monitoring must be performed within 3 hours
    - if received during normal working hours
           Receiving Packages
   Must notify NRC Operations Center if:
    – Excess contamination is found
       • 10 CFR 71.87(i)
    – High radiation levels - 10 CFR 71.47
   Must have written procedure for package
    opening and assure that it is followed
             Safety Training
           49 CFR 172.704(a)
   Emergency Response
   Measures to protect the employee
   Methods for avoiding accidents
          Emergency Response
   Notify final carrier and NRC if:
    – Radiation level greater than 200 mrem/hr on
      package surface
    – Contamination - averaged over 300 cm2
       • >22 dpm / cm2 beta/gamma, low toxicity alphas
       • >2.2 dpm / cm2 other alphas
       Immediate Notification of DOT
           Required by Carrier
          49 CFR 171.15 and .16
   Persons killed
   Injuries requiring hospitalization
   Carrier or other property damage >$50,000
   Evacuation of general public > 1 hour
   Major transportation artery shutdown for > 1
    hour
   Flight pattern or routine of aircraft is altered
   Fire, breakage, spillage or suspected radioactive
    contamination involving Class 7 shipment
    Immediate Notification of DOT
        Required by Carrier
       49 CFR 171.15 and .16
   Notice shall be given to DOT
   Notice involving aircraft made to FAA
   Notice involving etiologic agents made to
    CDC
   Info required using DOT Form F 5800.1
    – 10 CFR 171.15(b)
    Immediate Notification of DOT
        Required by Carrier
       49 CFR 171.15 and .16
   Written follow-up required in 30 days
   Does not apply to Limited Quantity
    shipments unless:
    – Incident must be reported as required by
       • 10 CFR 171.5(a)
    – Incident involves an aircraft
    – Materials in Packing Group I
    – Incident involves Hazardous Waste
         Measures to Protect the
              Employee
   Training (understand radiation safety)
   Protective Clothing
   Survey Meter (available, operational)
   Procedures
   Contamination Check
   ALARA
    – Time, Distance, Shielding
Methods for Avoiding Accidents
   Training
   Follow Procedures
   Check for Contamination
   Ask questions, if unsure
   Notify if ANYTHING unusual is noted
DOT Fines
                   DOT Fines
   $9,800 - Failure to brace packages; Failure to
    provide employee training; Inaccurate hazard
    labels; No shipper’s certification, etc.
   $3,975 / $4,990 - Failed to create and retain
    records of employee training and testing, etc.
   $4,710 - Did not use SI Units; Did not list RQ
    designation; No 24-hour number listed, etc.
   $6,160 - Used unauthorized Type A Package
   http://hazmat.dot.gov/hmenforce.htm
                   Summary
   Get copies of the current radioactive
    materials license when shipping to anyone
    – Required for Domestic Shipments
    – Recommended for International Shipments
   Read the Regulations
    – Maintain a current set of ALL pertinent
      regulations
   Keep COMPLETE Records
   Audit your program
                  References
   10 CFR 20    NRC Radiation Safety Rules
   10 CFR 71    NRC Transportation Rules
   49 CFR 107   Frequent Violations!
   49 CFR 387   Insurance
   49 CFR 171   General Shipping
   49 CFR 172   Tables & Communications Rules
   49 CFR 173   Shipping Requirements
                 References
   49 CFR 174    Rail Shipments
   49 CFR 175    Air Shipments
    – IATA Regs cover Air Shipments
   49 CFR 176    Boat Shipments
   49 CFR 177    Truck or Car Shipments
   49 CFR 178    Container Specifications
   49 CFR 179    Tank Car Specifications

								
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