ML19322A338

Review of DOT Regulations for Transportation of Radioactive Matls.

ML19322A338
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Site:	05000262
Issue date:	10/31/1977
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A Review of The Department of Transportation (DOT) l Regulations for Transportation

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U.S. Department of Transportation 1

Materials Transportation Bureau '

) Office of Hazardous Materials Operations October 1977 Washington, D.C. 20590 (l 9 09 'a403c;;2

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l TABLP OF CONTENTS Page list of Tables and Illustrations iii Title and Preamble 1 I BACKGROUND DISCUSSION 2

II SUP%\RY OF RADIOACTIVE ?'ATERI ALS TRANSPO!?TATION 3 REGU LATIONS A. Organizations 3

B. Federal Regulations 4 C. Othet Sources of Pegulations and Tariffs 6 III

SUMMARY

OF PRINCIPAL S!!IPPERS' PEQUIREITENTS I N' 7 PREPARATION AND OFFERING OF RADIDACTIVI. MATERIAL PACKAGES FOR SilIPMENT A. Best Approach to Using the Regulations 7 B. Special Form Radioactive Materials 7

} C. Normal Form Radioactive :Taterials 9 D. Quantity Limits and Packaging 10 E. Small Quantities, Devices, and Low-Speci fic 11 Activity Materials F. Type A PacLaging 12 G. Type B Packaging 14 H. Control of Radiation During Transport 15 (Transport Index)

I. Warning Labels 17

.J . Contamination Control 19 K. Othe,r Shipper's Requirements 21

1. Other package markings 21

2. Shipping papers 22

3. Shippers ' certi fication 22

4. Security seal 23

5. Small dimension 23

6. Liquid packaging provision 23

7. Surface temperature of package D 8. Quality assurance requirements 24 24 l

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11 Table of Contents (Continued)

Page I. . Fissile Radioactive Materials 24

?!. Clarification of Classification Terminology 25 IV CARRIFP RTQUIREMENTS IN ll\NDLING OF PADIDACTI\T 26 l MATERI ALS PACKAGES i A. Certification by Shipper 26

.l B. P.'acarding 26 l

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C. Stovare Control by Maxinum Transport Index 28

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n. Reporting of Incident s 28 E. Shipping l' apers 30 F. Notification to Pilot (for Aircraf t Fhipnents) 30 V. DISCUSSION OF t' ORE FRIQl'I:NTLY NOTFD DISCPEPANCIES 30 IN RADIOACTIVE NATERI ALS SillPMliNTS l

A. By Shippers 30 l B. By Carriers 33 VI IAEA REGULATIONS 34 VII RADIDACTIVF ?'ATEPI ALS DFFINITIONS 37 VIII REFERENCIS 39

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TABl.ES AND ILLUETRATIONS i Page Illustrations Figure 1 'b t >'u s t I Do to \ lake a Sa fe and Legal 1 Shipment of Radioactive :'aterials?"

Figure 2 Special Form Padicactive 'faterial 8 Figure 3 Normal Forr Padioactive 3!aterial 10 Figure 4 'lypical Type A Pacl iging Scheres 13 Figure 5 Typical Type B Packaging Schemes 14 Figure 6 Packare Labels 18 Figure 7 A Ford of Caution on Terminology 25 Figure 8 Vehicle Placards for Radioactive !!aterials 27 Figure 9 Interagency Radiolco ical Assistance Plan Map 29 Tables Table 1 Sources of Federal Regulations 5 Table 2 Other Sources of Regulations and Tariffs 6 Table 3 Type A and Type B PacLage Quantity Limits 11 Table 4 Activity Limits for Small Quantities, Devices 13 and Lou Specific Activity B'aterials Table 5 Radioactive 5'aterials F'aximum Radiation Level 16 Limitations Tabic 6 Radioactive Material Packages I.abel Criteria 19 Table 7 Radioactive Material Package Contamination 20 Limits Table 8 Most Commonly Used Shipping Names for RAM 22 Tabic 9 Shipment Controls for Fissi1e Madioactive 25 1'a terials Packages

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l A REVIEW OF THE DEPARTMENT OF TRANSPORTATION (DOT) i REGULATIONS FOR TRANSPORTATION OF RADIOACTIVE MATERIALS

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FIGURE 1 "What Must I Do to Make a Safe and Legal Shipment of Radioactive Materials?"

Perhaps some persons who have made shipments of radioactive materials may have felt'like the persor. illustrated above.

'The purpose of this Review is to summarize the basic reouire-ments of the Department of Transportation (DOT) regulations governing the packaging and shipment of radioactive materials and to provide guidance toward more correctly and easily apply-ing those regulations in actual practice.

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This Review is a reference and guidance type document for '

training purposes. It is not intended to be an official interpretation or restatement of the regulations. Any mate-Fial herein may be reproduced without special permission ).

from the Department.

Users of this Review are strongly encouraged to obt a the latest copy of the DOT Hazardous Materials Regulatit 3 in 49 CFR Parts 100-199, and to keep abreast of latest revisions thereto as they are published in the Federal Register.

( (This Review was compiled and edited by A. W. Grella, Chief, Technology Division, Office of Hazardous Materials Operations,

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DOT, from a series of 1ecture notes and visual aids which have been used in lectures and training sessions over the past several years.)

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2 I. BACKGROUND DISCUSSION Since the beginning of the relatively young atomic energy industry, i.e., about three decades, there has been an excellent record of safety in the transportation of millions of packages of radioactive materials. Recent estimates indicate that current shipments involve approximately 2,500,000 packages of radioactive materials per year in the U.S.A. Thus far, based on best available information, there have been no known deaths or serious injuries to the public or to the trans,ortation industry personnel as a result of the radioactive nature of any radioactive material shipment. This fact can generally be attributed to the close attention which has been given by the shippers to the proper pachaging of radioactive materials, and to the effectiveness of the safety standards and regulations applicable to tneir transportation.

Nothwithstanding the exec 11ent past record of safety, the term " radioactive" unfortunately conveys to the average person an extremely confusing aura of personal concern. The memory of thi devastating destruction and violent deaths which were the af termath of the use of the atomic bomb near the end of World War II is still very vivid in the minds of many. The more recent confusion regarding the ef fects of nuclear power plants on the environment and the ecology have m'so added to this aura of concern. This concern, however, has proven to {

be completely unwarranted as related not only to the safe uses of nuclear energy in indus try , but also to the safe transportation of radioactive materials. The record of safety in transportation of these materials clearly exceeds that for any other type of regulated hazardous cor.modity.

The current status of the private segment of the nuclear industry in the U.S.A. is such that the vast najority of the current shipments of radioactive raterials involves small or in'termediate quantities of material in relativelv small Pack-ages. !fost of these packages involveiradioisetopes which are intended for medical diagnostic or therapeutic applications by thousan'ds of doctors and hospitals throughout the U.S.A.

and elsewhere. Many such materials are quite of ten of very short half-life," and, therefore, must be supplied by the producer to the user via the most rapid available means of transportation. It, therefore, follows quite logically that the vast majority of these packages will involve air freight or air express via passenger-carrying or cargo-only aircraft.

Such shipments most often involve at least two modes of trans-port, i.e., air and highway.

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II.

SUMMARY

OF RADI0 ACTIVE MATERI ALS TRANSPORTATION REGI!LATIONS A. Organii ens Under the Depas . ment of Transportation Act of 1966, the U.S. Department of Transportation (DOT) has regulatory responsi-bility for " ty in the transportation of radioactive materials by all mods . .,f transport in interstate or foreign commerce (rail, road, air, water), and by all means (truck, bus, auto, ocean vessel, airplane, river barge, railcar, etc.), except postal shipments. Postal shipments come under the jurisdiction of the U.S. Postal Service, formerly known as the Post Office Department. Shipments not in interstate or fereign commerce are subj ec t to control by a state agency in most cases.

The Interstate Commerce Commission (ICC) formerly had the juris liction over both the safety and economic aspects of the transport of radioactive materials by land, but the jurisdiction over sa fety was transferred to the Department of Transportat ion when DOT was formed in April 1967. The ICC (for land shipments)

'and the Civil Aeronautics B ::rd (for air shipments) still exercise jurisdiction over the economic aspects of radioactive materials transport through the issuance of operating authori-ties to carriers, and control of shipping costs (freight rates).

I Under the Atomic Energy Act o f 1954, as amended , the U.S.

Nuclear Regulatory Commission (NRC) also has responsibility for safety in the possession and use, including transport, of byproduct, source and special nuclear materials. Except for certain small quantities and specific products for which the possession and use are exempted, a license is required from the NRC for possession and use of such materials. The NRC has established, in 10 CFR Part 71, reuuirements which must be met for liccasces to deliver licensed material to a carrier for transport if fissile material or quantities exceeding Type A are involved. The NRC also assists and advises DOT in-establishment of national safety standards and in review and evaluation of packaging slesigns.

Several states have entered into formal agreements with the NRC whereby the regulatory authority over byproduct , source and less than critical quantities of special nuclear material has been transferred to the states from the NRC. These

" Agreement States" have adopted uniform regulations pertaining I

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to intrastate transportation of radioactive materials which require the shipper to conform to the packaging, labeling, and marking requirements o f the U.S. Department of Transportation to the same extent as if the transportation were subject to the rules and regulations of that agency.

B. Federal Regulations

• The principal sources of Federal regulations pertaining to the transport of radioactive materials are listed in Table 1.

The regulations of the United States of America are published by three agencies--the U.S. Department of Transportation, the U.S. Nuclear Regulatory Commission, and the U.S. Postal Service.

This Review is concerned primarily with those regulations of the U.S. Department of Transportation, as published in Title 49, Code of Federal Regulations, Parts 100 through 199. Persons involved as actual shippers, package designers , or carriers ,

are advised to procure a copy of these regulations (all in one bound volume) which are republished each year as of October 1, by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. (As of 1977, the cost was

$6.5 0. ) Changes to these regulations, in the form of amend-ments or notices of proposed rule making are published in the daily Federal Register, as issued by the Materials Transportation 1 ureau~DITd) of the' DOT. Another means of keeping I abreast of changes would be to request in writing to be placed on the mailing list maintained by the DOT, Of: ice of Hazardous Materials Operations, Washington, D.C. 20590.

• Throughout this Review the paragraph references listed apply to pertinent paragraphs in Titic 49, Code of Federal Regulations, Parts 100-199, unless otherwise specified.

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5 TABLE 1 I SOURCES OF FEDERAL REGULATIONS Title 49 Department of Transportation's llazardous Materials Regulations, Parts 100-199 Main licadings 49 CFR 170 - Rule-making Procedures of the Materials Transportation Bureau 49 CFR 171 - General Information, Regulations and Definitions 49 CFR 172 - Ilazardous Materials Table and llazardous Materials Communica-tions Regulations 49 CFR 173 - Shippers-General Requirements for Shipments and Packagings 49 CFR 174 - Carriage by Rail 49 CFR 175 - Carriage by Aircraft I

49 CFR 176 - Carriage by Vessel 49 CFR 177 - Carriage by Public liighway 49 CFR 178 - Shipping Container Specifications 49 CFR 179 - Specifications for Tanks Cars Title 10 U.S. Nuclear Regulatory Commission 10 CFR 71 - Packaging of Radioactive Materials for Transport and Transportation of Radioactive Material Under Certain Conditions Titic 39 Postal Service, U.S. Postal Service Regulations, Part 123. (Postal Regulations for Transport of Radioactive Matter are published in U.S. Postal Service Publication #6, December 1975 and in the U.S. Postal Manual.)

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C. Other Sources of Regulations and Tariffs

• Other agencies or organizations which publish regulations or tariffs on the transportation of radioactive materials are as follows:

TABLE 2

1. "IATA Restricted Articles Regulations,"

20th Edition 1977 - International Air Transport Association (IATA). Geneva, Switzerland.

2. " Regulations for the Safe Transportation of Radioactive Materials," Safety Series #6, 1973 Edition - International Atomic Energy Agency (IAEA). Vienna, Austria.

3. " Official Air Transport Restricted Articles Tariff No. 6-D" - Airline Publishers, Inc.,

Washington, D.C.

4. "R. M. Graziano 's Tarif f No. 31, Hazardous Materials Regulations of the Department of Transportation, Including Specifications j for Shipping Containers , March 31, 1977" -

Bureau of Explosives, Association of American Railroads, Washington, D.C.

5. "ATA llazardous Materials Tarif f 111C ,"

Department of Transportation Regulations for Governing Transportation of Hazardous Materials by Motor, Rail, and Water, Including Specifications for Shipping Containers , August 1, 1977 - American Trucking Associations, Inc.

NUTE: Refer to the current edition of the above references.

• A word of caution here--a tariff should not he construed to be an official regulation per se. A tariff is merely a publi-cation by some originating association, which reprints certain Federal regulations, showing the application and acceptance of those regulations by the carriers who participate in the tariff. As such, tariffs are binding only on the organizations' or association's member carriers. If a person chooses to utilize the widely-used B of E Tariff No. 31 , as a source of the regula-tions, it is suggested that the subscription be for the loose-leaf version rather than for the bound version, since changes and amendments are much more easily posted hereto.

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The international regulations as promulgated by the International Atomic Energy Agency (IAEA) are discussed briefly in Section VI of this Review. Suffice it to say, the DOT regulations were almost completely revised as of January 1, 1969, to achieve substantial, but not complete , conforn.ity with the IAEA regulations. The regulations of the International Air Transport Association (IATA) are essentially identical to the IAEA regulations.

III.

SUMMARY

OF PRINCIPAL SilIPPERS' REQUIREMENTS IN PREPARATION AND OFFERING OF RADIOACTIVE MATERIAL PACKAGES FOR SHIPMENT A. Best Approach to Using the Regulations The primary consideration for achievement of safety in the transportation of radioactive materials is the use of proper packaging for the specific radioactive materials to be transported. Listed below are the three most basic questions that a prospective shipper or package designer must address himself to at the outset, in determining his packaging require-ments. These q2estions are as follows:

1. What radioisotope is being shipped? gl73.390 contains a listing of over 250 specific radionuclides plus certain " ground rules" for dealing with unlisted D or unknown radionuclides, or with mixtures or radionuclides.

2. What quantity of the radionuclides is being shipped? As we will see, the packaging requirements relative to quantity are essentially structured about the aggregate quantity in a package, in terms of curies, millicuries, or microcuries.

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3. What is the form of the-radioisotope?

a. Is the material in special form?; or

b. Is it in normal form?

The new terminology which has been introduced in asking these three questions will be enlarged upon in the succeeding paragraphs. i B. Special Form Radioactive Material _s_

What is meant by "special form" radioactive material?

As illustrated in Figure 2, we see that "special form" materials are defined as materials, which, if released from a package, might present a hazard due to direct, external radiation, but due to their high physical integrity, would present very little hazard, if any, due to radiotoxicity D

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8 as a result of spread of contamination. This high physical integrity could be the result of inherent property of the material, such as its being in massive, solid form or an ac-quired characteristic such as encapsulation as a scaled source. i Note a word of caution at this point: The DOT Specification 2R is often used as an approach toward "special form" encapsu-lation. DOT Specification 2R containment is not necessarily synonymous with "special form." In other words, each specific DOT Specification 2R encapsulation must be evaluated against  ;

the "special form" performance criteria as prescribed in the .

regulations (fl17 3. 398 (a) ) in just the same fashion as any l other prospective "special form" material. This determination, however, is left to the responsibility of the shipper' or package designer, as appropriate, and is not made by the DOT.

Recognizing that "special form" materials are much less likely to get " scattered around" in the event of package fa il u re ,

the regulations allow substantially larger quantities of such materials to be placed in given packagings, than if the materials were in " normal form."

FIGURE 2 "SPECIAL FORM" R.A.F. (173.389(G) AND 173.398(A))

i MAY PRESENT A DIRECT RADIATION HAZARD IF RELEASED FROM PACKAGE, BUT LITTLE HAZARD DUE TO CONTAMINATION "SPECIAL FORM" R.A.M. MAY BE " NATURAL" CHARACTERISTIC, l.E., MASSIVE SOLID METAL, OR " ACQUIRED" THROUGH HIGH INTEGRITY ENCAPSULATION

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For purposes of export, a shipper must furnish to the for-eign consignee a certificate of competent authority which is specific to the special form material. Such a certificate will only be issued by the DOT, Office of Hazardous Materials Operations upon receipt of a specific petition and only when a certificate is required by a shipper to fulfill a need.

Such a need will be in the case of foreign shipments only, pursuant to Marginal C-6.1 of the International Atomic Energy Agency (IAEA) Regulations or sections 6.2.6 and 9.3(i) of the International Air Transport Association (IATA) Regulations.

It should be noted, however, that for air shipments, the "special form" certification as prescribed in the Official Air Transport Restricted Articles Tariff No. 6-D, applies only to air shipments made from the U.S.A. to a foreign destination. 1 1

Notes 1 and 2 to gl73.398(a), relating to certain special form requirements are quoted below:

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• e .3 Nove 1: Ehsh al@ par of speelal fons reme-asuve oestertaa man manataan en sie ser et least one year after me inet esposat, and he prepared to provide the Departement, a seenplete certimentsen and supporttag safstr analysis (see Note 3) demonstrattag that the spoetal forma smaterial meets the requirementa of paragraph (a) of ele sectaos. This

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spoeial forma reenactive amaternal outside af the United states each ehlpper shall ehtaba a Certaaente of Coonpetent Authority for he ,

spectae maternat. aneh pettisen meet he esh-a ),and not addi y no ude 1 followtag taformation

1. A detened desertptica of the material.

er if a capsule 23 eentents, Portaeular tW.

esence mu=t be enade to both physsena med chemical states;

3. A detailed statessent of the design of any empeule to be used including ocamplete engineerlag drawings and ashedules of sam-

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.ona nod estr ,es.it.e .teste or wh:ch e - he.ed m, ealeelstfre siethods to show that the sam-terfalle encabas of meeting the tes'e. or othee evidense that the spoola! form radioactive materian sneets the requiremente of para-graphe (a)(1) thru (4) et this esottee.

C. Normal Form Radioactive Materials Illustrated in Figure 3 afe " normal form" radioactive materials which are,therefore,any materials which do not qualify as "special form." Normal form radioactive materials are classified into either of seven " transport groups" in the aforementioned table of several hundred radionuclides (@l73.390).

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INCLUDES ANY MATERIAL WHICH DOES NOT QUALIFY AS "SPECIAL FORM".

NORMAL FORM MATERIALS ARE CLASSIFIED INTO EITHER OF SEVEN TRANSPORT GROUPS.

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l D. Quantity Limits and Packagig Having now considered the type, quantity, and form of the I radioactive material, one is now ready to consider the packaging requirements. In doing so, one encounters terminology such as

" Type A quantity," " Type A packaging," " Type B quantity,"

" Type B packaging," "Large quantity," Small quantity,' " Radio-active devices," and " Low specific activity materials." In Table 3, there is a list of the Type A and Type B quantity limits for the normal form transport groups and for special form materials. Note here the extreme importance of the special form determination, since its quantity limit is independent of the transport group. For normal form materials, note that the increasing transport group numbers range from Group I, which includes the highly radiotoxic alpha emitters, such as plutonium, americium, and radium, to the less radiotoxic, higher transport groups.which have a higher allowable aggregate quantity per package. As indicated in a footnote to this Table, a "large quantity" of radioactiec material would be i any quantity which exceeds the specified Type B quantity limit.

" Type B quantities," "Large quantities," i.e., "Large sources," and " Fissile radioactive materials" present more unusual and specific packaging problems. These materials are l additionally controlled by the packaging standards as promulgated

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by the Nuclear Regulatory Commission in Title 10, CFR, Part 71, as well as the provisions of $173.398(c), 8173.395(c), or 8173.396 of Title 49.

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11 TABLE 3 Type A and Type B Fackage Quantity Linits TRANSPORT GROUP TYPE A QUANTITY TYPE B QUANTITY *

(Curies) (Curies)

I 0.001 20 II 0.05 20 III I 200 IV 20 200 V 20 5,000 VI, VII 1,000 50,000 SPECIAL FORM 20** 5,000

• Quantities exceeding Type B are "large quantity" (large radioactive source).

• • Except for Californium-252, wherein the limit is 2 curies.

I E. Small Quantities, Devices, and Low-Specific Activity Materials The transport group and special form package limits are also used as a basis for defining the package quantity for small or " exempt" quantities, manufactured articles, radioactive devices, and for low specific activity materials, as illustrated in Table 4. As a matter of interest , the "small" or exempt quantities and " radioactive device" categories are those which are allowable for shipment by U.S. Mail provided that certain other limitations are fulfilled. . Note in Table 4 that the limitations for low specific activity materials are based on concentration, i.e., specific activity, rather than on the aggregate quantity per package.

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TABLE 4 Activity Limits for Small Quantities, Devices and Low Specific Activity Materials TRANSPORT SMALL OR MANFT ARTICLES AND RADI0 ACTIVE LOW SPECIFIC GROUP EXEMPT DEVICES MAXIMUM OUANTITIES ACTIVITY QUANTITIES PER DEVICE

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PER PACKAGE MATERIALS I 0.01 mci 0.0601 Ci 0.0001 Ci 0.0001 mci /gm II 0.1 mci 0.001 Ci 0.05 Ci 0.005 mci /gm III 1 mci 0.01 Ci 3 Ci 0.3 mci /gm IV 1 mci 0.05 Ci 3 Ci 0.3 mci /gm V 1 mci 1 Ci 1 Ci VI 1 mci 1 Ci 1 Ci VII 25 Ci 25 Ci 200 Ci SPECIAL FORM 1 mci 0.05 Ci 20 Ci F. Type A Pac) aging In Figure 4, there is an illustration of typical " Type A package" schemes. Type A packaging is that whic'i must be designed in accordance with the applicable general packaging requirements as prescribed in the regulations ($173.393), and which must be adequate to prevent the loss or dispersal of its radioactive contents and to maint,ain its radiation shielding properties if the package is subj ected to the defined " normal" conditions of transport. The regulations prescribe (gl73.398(b))

the performance criteria to simulate these normal conditions of transport. Typically, as is seen, the Type A packaging provided for in the regulations is the purely performance-based DOT Spec. 7A, Type A general package, for which a shipper must make his own assessment of his particular package design against the performance requirements. The regulatory framework, therefore, provides for the use of all Type A packaging without specific regulatory approvals of the package designs via the use of.the DOT Spec. 7A performance specification. Additionally, foreign-made Type A packages are acceptable internationally, provided they are so marked as Type A, without specific approval by the competent national authority of either country. It

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13 D should be noted that the shipper of each DOT Spec. 7A is required to maintain on file for at least one year after the latest shipment, and be prepared to provide to the Department, a complete certification and supporting safety analysis demonstrating that the construction methods, packaging design, and materials of construction are in compliance with the specification (see ggl73.394(a)(1) and 173.395(a)(1)) .

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TYPICAL TYPE A PACKAGING PACKAGE MUST WITHSTAND NORMAL CONDITIONS 1173.398(B))

0F TRANSPORT ONLY WITHOUT LOSS OR DISPERSAL OF THE RADI0 ACTIVE CONTROL CONTENTS.

FIBERBOARD BOX WOODEN BOX STEEL DRUM TYPICAL SCHEMES DOT SPECIFICATION 7A TYPE "A" PACKAGE NOTE: A useful reference which aay be helpful in evaluating whether certain listed DOT specification package designs meet the requirements of DOT Spec. 7A is listed in Section VIII, Item 15.

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14 G. Type B Packaging With respect to Type B packaging (see Figure 5), this involves packaging which must be designed to withstand, in addition to the general packaging 'quirements and the per-formance standards for normal conditions of transport, certain serious accident damage test conditions with resultant limited loss of shielding capability and essentially no loss of con-tainment. The performance criteria which the package designer must use to assess Type B packaging against these empirically established accident damage test conditions of the transport are prescribed in the regulations (8173.398(c)) and include l the following:

1. A 30-foot free drop onto an unyielding surface.

2. A puncture test which is a free drop over 40 inches onto a six-inch diameter steel pin.

3. Thermal exposure at 1475 0-F for 30 minutes.

4. Water immersion for eight hours (for fissile

materials packaging only).

FIGURE 5 TYPICAL TYPE B PACKAGING SCHEMES I

PACKAGE MUST STAND BOTH. NORMAL (173.398(Bl] AND ACCIDENT II73.398[Cil TetT C0lelTl0NS WITHOUT LOSS OF CONTENTS.

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Except for a limited number of specification Type B pack-agings (i.e., DOT-6M) described in the regulations, all Type B package designs require prior approval of the U.S. Nuclear Regulatory Commission. (See gl73.393a for standard requirements and conditions pertaining to such approved packages.)

As mentioned earlier, "large quantities" of radioactive material are defined as those quantities which involve greater than " Type B" quantities. The most common materials involved es large quantities are the high-curie irradiator sources cnd irradiated fuel materials. Packaging requirements for i large sources involve all of the Type B packaging requirements plus other provisions for such things as decay heat dissipation, potential leakage of contaminated heat transfer medium, heavier shielding, and the like, which in some cases, may involve a requirement for certain administrative controls peculiar to the specific package design during shipment.

H. Control of Radiation During Transport (Transport Index)

The regulations prescribe that the maximum permissible dose rate at contact with the accessible exterior surface of cny package of radioactive materials offered for transport shall not exceed 200 mr/hr, or 10 mr/hr at three feet (this latter value being equal to the maximum " Transport Index").

D Higher dose rate 3 are also prescribed, which are allowable provided that " sole use" of the transport vehicle is assured by the shipper. The radiation level limitations are summarized in Table 5. To control the radiation level of accumulations of multiple numbers of packages once in the transportation environment, the regulations require that the carrier shall main-tain certain prescribed separation distances between radioactive materials packages and other areas which are continuously occupied by persons and/or photographic film. These separation distances relate the storage time against the " Transport Index", which was defined previously as the dose rate in mrem /hr at three feet from the accessibic exterior surface of the package. No package offered for transport (in other than sole-use vehicles) may have a transport index exceeding

10. The establishment of this maximum transport index of 10 is based on considerations for prevention of " fogging" of

" fast" photographic film. The total transport index of any eggregate number of packages in any single transport vehicle (other than a sole-use vehicle) or storage location may not cxceed 50. The regulations provide graded tables of stowage distances vs. time for stowage in accordance with the cumulative transport index. These tables are found in the carrier sections of the regulations (g8174.700, 17 7. 84 2 (b) , 176.700, and 175.700.

_____ - -

16 TABLE 5 {

RADIDACTIVE MATERIALS MAXIMUM RADIATION LEVEL LIMITATIONS (SEE 173.393[l) AND 0))

RADIATION LEVEL l0OSE) RATE AT ANY POINT ON EXTERNAL SURFACE OF ANY PACKAGE 0F R A M. MAY NOT EXCEED :

A. 200 MILLIREM PER HOUR.

R 8.10 MILLIREM PER HOUR AT THREE FEET ILRA3$PDRI.IND01 MAY NOT EXCEED 10).

J ill THE PACKAGES ARE CONSIGNED TO A ' SOLE USE" OR" EXCLUSIVE USE" UN CLOS,ED TRANSPORT VEHICLE (EXCEPT AIRCRAFT) THEN THE MAXIMUM RADIATION LEVELS MAY BE:

A.1000 MILLIREM PER HOUR AT 3 FEET FROM EXTERNAL PACK ACE SURFACE.

8. 200 MILLIREM PER HOUR AT EXTERNAL SURFACE OF THE VEHICLE.

C.10 MILLIREM PER HOUR AT 6 FEET FROM EXTERNAL SURFACE OF THE VEHICLE.

D. 2 MILLIREM PER HOUR IN ANY P0$lil0N OF THE VEHICLE WHICH 15 OCCUPIED BY A PERSON.

The transport index (T.I.) system, together with tables of separation distances, provides control by the carrier over the radiation exposures to personnel handling the packages, or to casually exposed persons in the vicinity of accumula-tions of packages.

The T.I. system is also designed to provide the means fcr carriers to limit aggregation of packages of fissile radio-active materials, so as to assure nuclear criticality safety, e.g., the prevention of the assemblage in one location of an amount of fissile material which, under credible conditions ,

would support a nuclear " chain reaction," i.e., "go critical .'

For such materials, the shipper must determine, in accordance with regulatory criteria (NN10 CFR 71.37 through 71.40), the appropriate T.I. criteria based on nuclear criticality safety.

For purposes of transportation, he then must assign to the package the higher of the T.I. values as based on either the nuclear criticality safety criteria or the radiation IcVel limitation (as described e arlier) .

During transportation, the carrier, therefore still makes reference to the T. I. and st, wage tables, even though for fissile materials, the T.I. n y be based on criteria other

i

. 1

.

17 than the external radiation IcVels. For this reason, it is

}

important to recognize that, the absence of measurable exterior radiation levels from certain types of fissile radioactive materials packages, would not necessarily constitute an "overlabeling" violation.

I. Warning Labels Each package of radioactive material, unless exempt, must be labeled (8172.403(f)) on two opposite sides, with a distinctive warning label. . Each of the three label formats, as described in 88172.436 through 172.440, and Figure 6, bears the unique trefoil symbol. This symbol was recommended by the International Commission on Radiation Protection (ICRP) in 1956 and has been adopted by the American National Standards Institute as the standard radiation symbol (N2.1-1969). The label alerts persons handling packages that the package may require special handling. If the back-ground color of the label is all white, the radiation is minimal and nothing special is required for that package.

If, however, the background of the upper half of the label is yellow, a radiation level requiring consideration may exist at the outside of the package and an indication of what controls must_be_ exercised for that package is related to the transport in'dex concept. If the package bears a yellow label, withthree stripes, the rail or highway vehicle in which it is carried must be placarded. Placarding is discussed I in more detail in Section IV. The criteria which the shipper must consider in choosing the appropriate label are listed in Tabic 6.

I

'

.

18 FIGURE 6 PACKAGE LABELS RADIOACTIVE-WIIITE I RADIOACTIVE 'iELLOW II RADI0 ACTIVE-YELLON III

.

s .

he ',

.

he \ 'N heh

/ 4 'N, & &

HI0dThE / JJWIIVETF' _NRTIVEyF'

=1 / 91,- mill /

N'/ '

,,/ p

(See gl72.436) (See 8172.438) (See 8172.440)

For all labels, vertical bars overprinted in lower half of each label are in red. Each label is diamond shaped four inches on each side having a black solid line border one-fourth inch from the edge.

The regulatory provisions in gl72.403(f)(1) applicable to the use of these labels are quoted as follows: l

"(f) Each package required by this section to be labeled with a RADIOACTIVE label must have two of these labels, affixed to opposite sides of the pack-age.

(1) The applicable information as required in any blank spaces on the RADI0 ACTIVE label must be inserted by legible printing (manual or mechanical),

using a durable, weather resistant means or marking."

In addition, the following requirements apply to completion of the items of information in the blank spaces of the labels specified in this section:

(1) " Contents" - The name of the radionuclide, as taken from the listing of radionuclides in 8173.390 (symbols which conform to established radiation protection terminology are authorized, i.e., 99310 , 60C o, etc.). For mixtures of radio-nuclides on the basis of radiotoxicity must be listed as space on the label allows.

(2) " Number of curies" - Units shall be expressed in appropriate curie units, i.e., curies (Ci), millicuries (mci) or microcuries (uCi) (abbreviations are authorized) . For a fissile (

material, the weight in grams or kilograms of the fissile radio-isotope may also be inserted.

(3) " Transport Index" - (See gl73.389(i))

19

) TABLE 6 RADIOACTIVE MATERI AL PACKAGES LABEL CRITERIA (173.399)

DOSE RATE LIMITS AT ANY POINT ON AT THREE FEET FROM LABEL ACCESSIBLE SURFACE EXTERNAL SURFACE OF OF PACKAGE PACKAGE (TRANSPORT INDEX)

" RADIOACTIVE-WHITE I" 0.5 mR/hr 0

" RADIOACTIVE-YELLOW II" 50 mR/hr 1.0 mR/hr

" RADIOACTIVE-YELLOW III"* 200 mR/hr 10 mR/hr

• Requires Vehicle Placarding (This label mandatory for any fissile Class III (173.389A) or large quantity package (173.389B), regardless of dose rate IcVels.)

J. Contamination Control The regulations prescribe limits (8173.397) for control of removable (non-fixed) radioactive contamination and pro-vide a definition of the term "significant removable contamina-l tion" as shown in Table 7. In general, the significant con-tamination level limit is applicable to any package offered for transportation (8173.393(h)) and also to any transport vehicle which is being released after having been used exclusively for transport of " full loads" of radioactive materials (88173,397(c)and 173.389(o)).

. _ _ _ _ _ _ _ _

_ _ .-

20 TABI.E 7 l

RADIOACTIVE MATERIAL PACKAGE CONTAMINATION LIMITS

I

,

$ 173.397 Contaminnellen eenerut.

l (a) 3tesnotable (non-fbsed) radio.

acuve contaminatten 8. aa==iw seg.

mascant at the level of contamination, when averased over any area of 300 square contameters of any part of the pne==e surface. =ceeds av et me .a

q l

4 ronowins.

o-- 9x  :~

- .cC"

(

l l

me

,

bamLW""*** ~

c  : ' e' C"3 "m. e -""= -

Aa seher_ alpha emhales rees.

. w* 23 (D In anecesing the surface contamin.

suon of a package, a sufnelent ruirnhar of l

'

measurementa muni be taken in the most appropriate locauons ao as to ytand a rep- k t meantative assesame.nt of the contasal.

>

' nation altantion. *111e avermas ==in=rnt of resnovable (non-ftned) radioactive con-tamatnation may be determined by wiping to esternal surfmes of Wie narbama with an absortent material, using anoderate pnesure. and then measuring the ne417 Its on the wtptng matertal If the mean. I ured activity per aquare cenumeter does met osesed It poetent of the leveh pre.

saribed ahose, 84 may he memummed that those levels have not boenn enmaammet.

Ottest--- t nianhasta et equal or greater secesocy may atmo be unan a ,

. th) Wham.radiomettre.unstertak pask-essa are ^ a as esclamite uma, se in g 19J0043), nesevatte ass-unSunsege ammemmaan.nana snay et at ligese het as spaniasd an ts)ta) of ele seemism.

t W'heh tusasport votests'uned der

% ammeertaas en an.

elumsut me, as amened In EIW3898W4

'

suust be surveyed trit acesupriate radia-stem .detecuon. Instsuments after each

!

'.ese. 4 may not to returned to servloe imets radianen anse rate at one asessushie see la es maangma

.Je heer er leek teselemealentS.

cast reenovable redseneuve surface een.

""*d IIB paragregIt (a)

_ - _ . - _ -_

. _ . . - _ _

21 I

K. Other Shipper's Requirements naving selected the proper packaging for the specific con-tents, and having considered the radiation level limits, contami-nation limits, and the label requirements, the shipper must also check for complia ce with the following:

1. Other package markings - the outside of the package must also be marked with the appropriate specification number (see 8173.24(c)(i)) or certificate number, if applicable, and also with the proper shipping name as shown in the list of hazardous materials (see gl72.101).

The pertinent regulatory requirements for marking of radioactive materials packages are quoted below:

"gl72.310 Radioactive materials (a) in addition to any other markings required by this subpart, each package containing radioactive materials must be marked as follows:

(1) Each package of radioactive materials in excess of 110 pounds (50 kilograms) must have its gross weight plainly and durably marked.on the outside of the package.

I (2) Each package of radioactive materials which conforms to the requireinents for Type A or Type B packaging (88173.389(j) and (k) and 173. 398 (b) r.nd (c) of this subchapter) must be plainly and durably marked on the outside of the package in letters at least b-inch (13 mm.) high, with the words " TYPE A" or " TYPE B" as appropriate. A packaging which is not in compliance with these requirements may not be so marked.

(3) Each package of radioactive material destined for export shipment must also be marked " USA" in conjunction with the specification marking, or other package certificate identification. (See

$$173.393a and 173.393b of this subchapter.)"

The most commonly used proper shipping names for radio-active materials are listed in Table 8.

I

22 TABLE 8 MOST COMMONLY USED SHIPPING NAMES FOR RADIOACTIVE MATERIALS (RAM)*

(FROM 172.101)

Radioactive Materials, Small Quantity, n.o.s (see 5173.391(a))

Radioactive Device, n.o.s. (see 8173.391(b))

Radioactive Materials, Fissile, n.o.s. (see 8173.396)

Radioactive Materials, Low Specific Activity or L.S.A., n.o.s. (see 8173,392)

Radioactive Materials, Special Form, n.o.s. (see 5173,394)

Radioactive Materials, n.o.s. (see 3173.395)

Uranium Hexafluoride, Fissile (containing more than 0.7% U-235) (see gl73.396)

Uranium Hexafluoride, Low Specific Activity (containing 0.7% or less U-235) (see 8173.392)

• Refer to 172.101 for other proper shipping names.

2. Shipping papers - Certain essential elements of infor-mation must also be included on the shipping paper descrip-tion (see 8172.203(d)). These requirements also apply to packages containing small quantities and radioactive {

devices (S173.391), except that the notation "no label required" must be entered in lieu of the type of label applied.

3. Shippers' certification - The shipping papers must include a certificate signed by the shipper.

(a) The following statement is required by Section 172.204(a) and must be used by July 1, 1979. (Ref.

Docket HM-112, April 15, 1976.)

"This is to certify that the above-named materials are properly classified, described, packaged, marked and are in proper condition for transportation according to the applicable regulations of the Department of Transportation."

NOTE: Preprinted certificates complying with 49 CFR 173.430(a) in effect on June 30, 1976, may be used through June 30, 1979.

(b) The following language may be used for shipments via air transportation in place of the statement in example (a) above.

l

. - _ _ - - _

_ _ _ _ _ _

.

.

23 "I hereby certify that the contents of this consign-ment are fully and accurately described above by proper shipping name and are classified, packed, marked and labeled, and in proper conditions for carriage by air according to applicabic national governmental regulations."

The requirements and limitations for carriage of radio-active materials aboard aircraft are prescribed in 8817 5. 7 5 (a) (4) , 175.85(d), 175.700, and 175.710.

4. Security seal - The outside of each radioactive mate-rials package must incorporate a feature such as a seal, which is not readily breakable and which, while intact, will be evidence that the package has not been illicitly opened (8173.393(b)). For this requirement, some ingenuity may be called for on the part of the package designer, especially on such packages as fiberboard cartons and wooden boxes. The regulations also require that " inner shield closures must be positively closed to prevent loss of . contents." In connection with these requirements, the sorry experience of the past has proven that too often an attempt has been made by shippers to utilize a padlock as both a security seal and a closure mechanism. Most padlocks, however, are not even a good security seal, let l alone a closure device, because it is usually not possibic with most types of padlocks to ascertain if they have been illicitly opened. Such combinations as serially numbered lead wire seals, in combination with such closure mecha-nisms as slotted screw-in plugs, bolted flanges, and positive-active shutter mechanisms are usually the best approach toward meeting the dual requirements.

5. Small dimension - The smallest outside dimension of any radioactive materials package must be four inches or greater (8173.393(c)).

6. Liquid packaging provision (S173.393(g)) - Liquid radi, active material must be packaged in or within a leak-resistant and corrosion-resistant inner container.

In addition, (1) the packaging must be adequate to prevent loss or dispersal of the radioactive contents from the inner container, if the package were subjected to the 30-foot drop test prescribed in 8173.398(c)(2)(i); and (2) enough absorbent material must be provided to absorb at 1 cast twice the volume of the radioactive liquid contents. The absorbent material may be located outside l l

!

24 I

the radiation shield only if it can be shown that if the radioactive liquid contents were taken up by the absorbent material the resultant dose rate at the surface of the package would not exceed 1,000 millirem per hour. Care should be exercised by the package designer to assure that the positioning of the absorbent material about the liquid-containing vessel is such that the absorber will absorb" in the event of leakage from the vessel. An alternative is provided to the use of the absorbents in that a secondary outer leak-resistant and corrosion resistant containment vessel may be utilized which must have the ability to retain the radioactive contents under normal conditions of transport, assuming the failure of the innermost primary containment vessel.

7. Surface temperature of package - b'aximum surface temperature limits on packages, resulting from radioactive thermal decay energy of the contents are prescribed in 817 3. 393 (c) . The limit is either 1220F or in the case of full load or sole-use shipments, 1800F.

8. Quality assurance requirements (8173.393(m) and (n))

The regulations also prescribe certain quality assurance requirements before the first shipment of a radioactive materials package (N173.393(m)) and before each shipment of a package (@l73.393(n)). With regard to packages of liquids containing in excess of Type A quantity, destined for shipment by air, an additional requirement (gl73.393(n)

(7)) is imposed such that the containment system of each package offered fer shipment must be tested to assure that it will remain leak-free in a specified ambient reduced atmosphere (0.5 atmosphere).

L. Fissile Radioactive Materials In addition to considerations for the radioactive content, shippers of fissile radioactive material must also take into account certain other packaging and shipment requirements to ensure against nuclear criticality due to the fissile (fission-able) nature of the materials. The design of the packaging for fissile radioactive material, the transport index to be assigned (if Fissile Class II), and any special procedures for packaging are prescribed in 49 CFR 173.396 of the DOT <

regulations and in 10 CFR 71 of the USNRC regulations. Each I fissile radioactive materials package design (except for the l DOT Spec. 6L, 6M, and Spec. 20 PF 1-3 and 21 PF 1-2) must l be reviewed and approved by the USNRC prior to its first use.

The packaging must be such to ensure against nuclear criticality (an unplanned nuclear chain reaction) under both normal and

. _ _ _ _ _ __ _

_ _ _ _ _ _ _ _ _ _ , _ _ _ _

l 25 I

accident damage test conditions, and prevent loss of contents under normal conditions of transport. For purposes of control in transportation, fissile radioactive material packages are classified into one of three groups , according to the degree of control which must be exercised to assure nuclear criticality safety, as shown in Table 9.

TABLE 9 SilIPMENT CONTROLS FOR FISSILE RADI0 ACTIVE MATERIALS PACKAGES (173. 389 (a) )

1. Fissile Class I - Packages may be transported in unlimited numbers (Transport Index is based only on external radiation levels).

2. Fissile Class II - Number of packages limited by aggregate maximum of Transport Index of 50 (50 unit rule). No singic package may exceed a Transport Index of 10. Trans-port Index will have been calculated either on criticality or external radiation level basis.

3. Fissile Class III - Packages which do not meet the require-ments of Fissile Class I or II. Controlled by special arrangements between the shipper and carrier. (See 173.396(g).)

=.

M. Clarification of Classification Terminology At this point, it is appropriate to offer the following word o f:

FIGURE 7 CAUTION - - - DO NOT CONFUSE THE FOLLOWING:

TRANSPORT GROUPS I THROUGH Vil (173.389(H) AND 173.390)

WITH :

RADIDACTIVE MATERIALS PACKAGE LABELS (172.403 AND 172.436 THROUGH 172.438)

'

RADIDACTIVE WHITE-l RADIDACTIVE YELLOW-il

,

RADIDACTIVE YELLOW-Ill OR WITH:

FISSILE CLASSES I, II, OR lli (173.389[A))

_ _ ____ _ .__

26 IV. CARRIER REQUIREMENTS IN HANDLING OF RADIOACTIVE MATERIALS 4

PACKAGES Up to this point, this Review of the regulations has been concerned principally with the regulatory requirements applica-ble to the shipper, or in some cases indirectly, to the pack-l age designer. The reason for this is simple. Most of the regulatory requirements for the assurance of safety in the trans-port of radioactive materials are directly towards safety through proper packaging. It follows, t here fo re , that the majority of these requirements will be ones which must be met by the shipper. The principal carrier responsibilities in transport of radioactive materials are as follows:

A. Certification by Shipper Carriers may not accept for transport any packages of radioactive materials which have not been properly certified by the shipper pursuant to gl72.204. This certificate is relied upon by the carrier, as evidence that the packaging is in accordance with the regulatory requirements. In the case of air shipments , one signed copy of the shipper's certificate must accompany the shipment, with the originating air carrier retaining a second copy (ggl75.30(a)(2) and 175.35(a)) .

B. Placarding

(

The carrier must apply the appropi placard to the transport vehicle (rail or highway) if,. RAM package on board bears a " Radioactive YELLOW-III" label (ggl74.541(b) and 177.823(a)(1)) . The famnts for the placards which are required prior to January 1, 1978 are illust' rated in Figure 8.

,

l

_ _ _ _ _ _ _ _ _ _ _ _

27 FIGURE 8 I

VEHICLE PLACARDS FOR RADIDACTIVE MATERIALS RAll MOTOR VEHICLE

[174.541 174.553) (177.823All)

--

ORADl01CTI4

~

_. a

"""""'" "

BLACK LETTERS OF 5/8 INCH STROKE

,.= , , ,

ON YELLOW BACKGROUND PLACARD MUST BE LARGER THAN LETTERING THEREON BY AT LEAST IA OUS ONE INCH AT TOP AND BOTTOM

[TY AL A 9, GARD SIZE IS l RADIDACTIVE MATERIAL As9 9,,

-

m Aound ammass h tumbene

=;.=-

I PLACARD IS TO BE DISPLAYED ON FRONT, REAR, AND EACH SIDE OF TRANSPORT VEHICLE A Word of Caution - Placarding of Full-Loads of LSA Radioactive Flaterials Questions occasionally arise about the placarding require-ments for " full-load" (sametimes referred to as " exclusive-use" or " sole-use") shipments of low specific activity radioactive materials (LSA). Under the shipper requirements of gl73.392(c)

(7) such LSA shipments must lie placarded by the shipper, with the same placard normally required to be applied by the carrier (pursuant to gl74.541(b) or 177.823) . Some persons have apparently misinterpreted the provisions of fl173.392(c)(7),

assuming that if the full-load shipment of LSA materials bears no packages with radioactive Yellow-III labels, then placarding would not be reauired. This is not the case. In fact, the packages in such shipments are excepted from pecification packaging, marking, and labeling pursuant to gl73.392(b). The ,

requirement to placard is, there fore , imposed on the shipper j rather than the carrier, which is certainly consistent with 1 the higher external radiation levels of 8173.393(j ) which are allowed for such full-load shipments. The reference to ggl74.

541(b) and 177.823 which is found in S173.392(c)(7) is, therefore, l for the purpose 'of citing the placard format only and should not be confused with a reference to the carrier's regular placard requirement based on Yellow-III labels.

. - _ _

28

-

NOTE: On January 1, 1978, the standardized vehicle placard for {

radioactive shipments will be as illustrated below.

Detailed requirements for this new 10 3/4" on each side placard are found in 8172.556 and Appendix B thereto.

"8172.556 Radioactive placard (a) Except for size and color, the radioactive placard must be as follows:

, /N

/ x K N

\

ADIDACTIV

/

,

/

\

\ /

/

s /

\ #

N /

'

\

s/

(b) In addition to meeting the requirements of 8172.519, and Appendix B to this part, the radio-active placard must have the top portion yellow with the symbol black. The lower portion must be white and the inscription black."

C. Stowage Cc'ntrol by Maximum Transport Index The carrier must assure that the total transport index does not exceed 50 for any group of " yellow-labeled" packages in a single transport vehicle or storage location, and further he must assure that such groups of yellow-labeled packages are kept separated from undeveloped film shipments and areas continuously occupied by persons, in accordance with a table of storage time vs. the grade! total transport index (HS174.700(c), 175.700, 176.700, and 177.842(b)).

D. Reporting of Incidents lie must assure that th'e shipper and the Department are notified in the event of fire, accident, breakage, or suspected radioactive contamination involving shipment of RAM and also that vehicles, areas, or equipment in which RAM may have i spilled, are not placed in service again until they have been j

( surveyed and decontaminated (@@l74.750, 171.15, 171.16, 175.45 ,

l (a) (4) ,176.48(b) , and 17 7.861(a)) .

.

.

29.

I The reporting requirement cited above is not necessarily a means of receiving technical assistance in radiological monitoring in the event of a transportation incident. To obtain such assistance, any person may call upon the services of the IRAP (Interagency Radiological Assistance Plan) . The map of regional coordinating offices and telephone numbers illustrated in Figure 9. Since its inception, many years ago, the IRAP has served to assist many persons in obtaining technical guidance in coping with radiation emergencies.

The IRAP organization works closely with other State, Federal, Military, and regional groups in integrating the technical capabilities of those groups.

FIGURE 9 U L ENERGY RESEAACH A40 OfVELOPUE41 ADM14t$f AATION REGIONAL COORDINATING OFFICES n uoioN at 'on tiieracai *"

COORDIN Af 4No OffKI f.e ARIA 908 Of flC E A 005111 A11111ANCE CODI RADIOLOGICAL ASSISTANCE

,,,,

0, ..,oo A nA on,C Avi,N

. . . . . .

. . . ,

-- -

GEOGRAPHICAL AREAS OF RESPONSIBilliY o.. oo. . . . .

l ,

(2) orie AnoNs ,, , ,;,7,,,,, . . . . . -

Of f tC E 5AVANNAM p -- [ b*e *

.Q OPit i CNS a eec i i

@ -J \_, e

..

--

%

.

1. '

j j '

"

At sgovt t o ug , , , , .

.**.

g q_ *ase 4 OPle Af TONS m m. ent ,,

Y_e e. 1 Of flC E

'

'.; E=

g, ' '

(s) o@T@' !i" 30AMO

~

4 , , , , , , , , ,

c% OrtaAT N$ pm [,,',

m

,,,

(7)lAN o't,,'g99 * > ANCISCO

,,~; ,, -- =

...... ...... . . . . . ....... ,,C,,,A,,,

...j c,.,.g %.....g 3

0..g o.s_ (p*=~' E - -

. __ . _ - -_ . _ _

,

1

.

30 l

E. Shipping Papers Carriers must prepare and carry with the shipments the appropriate shipping papers based on the information derived from the shippers' shipping papers (88174.24, 175.35, 177.817, and 176.24). For water shipments, a Dangerous Cargo Manifest or storage plan is also required (M176.30).

F. Notification to Pilot (for Aircraf t Shipments)

The aircraft operator must notify the pilot in command in writing of the aircraft of the name, type of label, quantity, and location of any " hazardous material," such as radioactive materials packages. The cargo load manifest must be conspic-uously marked to indicate the presence of such packages (49 CFR 17 5. 33) .

V. DISCUSSION OF MORE FREQUENTLY NOTED DISCREPANCIES IN RADIOACTIVE MATERI ALS SIIIMTI:NTS This discussion is intended to serve as an aid to both shippers and carriers by making them more aware of the nature of the more frequently observed items of noncompliance in radioactive materials shipments. Such items are generally either of a safety related nature, i.e., improper packaging, excessive radiation or contamination, or an administrative {

nature, i.e., improper shipping paper description, illegible labels, etc.

~

A. By Shippers

1. Excess radiation levels (gl73.389(i)) - Fortunately, this item is not noted frequently. It does, however, rank along with improper packaging, as the most serious type of shipper violation of the sa fety requirements for transportation of radioactive materials. Excessive

~

radiation 1evels on packages of radioactive materials are generally the result of either of two causes:

a. An excessive quantity of material in the package relative to the shiciding capability of the package design; or

b. A failure to properly secure a shicided closure mechanism, a faulty closure mechanism, etc.

l l

_. ___

For "special form" radioactive sources the hazard then becomes one of excessive radiation levels. For dispersi-ble, non "special form" radioactive materials, the hazard may then be due to both excessive radiation and possible dispersal of loose contamination. In some cases, it has been noted that suppliers of radioisotopes of very short half-life will place into their pacPages at the time of loading more than the total quantity allowed for shipment with the view that at the time of actual shipment, the radiation levels will be within the limits, due to radio-active decay. Such a practice can, of course, result in a violation if the package is offered for shipment too soon, with the radiation level not having decayed to the point of being within the limits.

2. Improper packaging - This , of course, is also a most serious safety item and is closely related to the excessive radiation level in that an improper package may be one which does not incorporate sufficient thickness of shield-ing for the quantity of material involved. Improper packaging also may result from not using a container as authorized in the regulations or under en exemption or other specific approval.

l Even when an approved package is utilized, however, if it is not in its proper condit' ion as required by its design, safety may be af fected. Good quality control practices by shippers of radioactive materials are para-mount. A relevant requirement of 173.22 reads as follows:

" ...the shipper shall be responsibic to determine that shipments of hazardous materials are made in containers which...,' have been made, assembed with all their parts or fittings in their proper place, and marked in accordance with applicable specifica-tions..."

The above provision is cited as a reminder to shippers that no package will perform during transportation as is intended by its original design, unless it is in its proper design condition, i.e., "as good as new" when offered for transportation. The quality assurance requirements of 173.393(m) and (n) serve to clarify these aspects.

I

32

3. Lack of security seal ($173.393(b)) - This requirement appears to be the Icast understood and most frequently noted type of discrepancy by shippers of radioactive mate-rial. It is really a performance type requirement, wherein--

"The outside of each package must incorporate a feature such as a seal, which is not readily breakable and which, while intact, will be evidence that the package has not been illicitly opened."

On some types of packages, i.e., steel drums, hinged lid boxes, etc., provision for a security seal is fairly simple. On many other types, i.e., wooden boxes, fiber-board cartons, much more thought and ingenuity in design-ing of a seal to meet the requirements will be necessary.

The use of padlocks as a security seal may not, in all cases, be appropriate since many types of padlocks may be illicitly opened and closed again without knowledge of the consignee.

4. Improper labels - Incorrect labeling of radioactive materials packages is a common deficiency. The most frequent error is "overlabeling," i.e., the use of a YELLOW-III label where a WHITE-I or YELLOW-II label would have been adequate. When done too often, such "overlabeling" can cause a loss in the distinction I which is intended to be implied by the graded series of the three labels which are used to indicate the degree of co'ntrol the package requires.

5. Illegible / incorrect label notations - This item should speak for itself. Needless to say, shippers should exercise care to insert legible, durable entries on the labels. These entries call for noting the " contents,"

" number of curies'," and " transport index." In recent rule making, more precise guidance has been provided on this aspect. The entry of "n.o.s." for "not otherwise specified" under " contents" is totally inappro-priate. The name of the isotope must be entered, as taken from the list of radionuclides in 173.390. Also, care should be taken to clearly indicate in the " number of curies" entry whether the quantity is in terms of curies, mil'licuries or 'mitrocuries. Finally, the " transport index" must be rounded up to the next highest tenth as prescribed in gl73.389(i).

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6. Improper or incomplete shipping paper description -

The basic requirements for the shipping paper description are prescribed in Subpart C, 8172 and 172.203(j) . The first entry on the shipper's bill of lading should always be the applicable " proper shipping name" as taken from the commodity list in 8172.101. Any other description or information not inconsistent therewith may follow.

Ilowever, there are at present 13 different proper shipping names for radioactive materials in the commodity list.

The most commonly used names are listed in Tabic 8 on page 22. The appropriate one of these must be used.

Care should be exercised to properly enter the other infor-mation as required by 817 2. 20 3 (j ) . When the shipment involves a radioactive material prohibited from transport by passenger-carrying aircraf t , the description shall also include the words " cargo-only aircraf t.

7. Inadequate provision for liquid contents - The regula-tions prescribe certain additional packaging requirements for liquid radioactive materials. As required by 8173.

393(g), these are basically the " performance" requirements wherein the package must withstand a 30-foot drop test without loss of liquid contents, and the use of absorbent material to absorb the liquid contents in event of breakage of the primary liquid container, or an an alternate I a double containment vessel system.

B. By Carriers

1. Acceptance of consignments without shipper's certifica-tion - Each of the carrier regulations prescribe a require-ment that shipments of regulated hazardous materials may not be accepted by a carrier unless accompanied by the appropriate certification by the shipper that the packages have been packaged, marked, and labeled in accordance with the regulations. This certification must be signed by the shippe'r and it is his legal representation to the carrier that the safety requirements of the shipment are in order. Needicss to say, carriers must refuse acceptance of hazardous materials shipments which are tendered to them without this certification.

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2. Failure to prepare proper shipping paper description -

Each of the carrier regulations require that carriers' {

manifests, waybills, etc., carry the appropriate proper  !

shipping name and an indication of the type of label applied or the notation "no label applied," when applica-ble. In many cases, carriers in preparing their shipping papers, do not properly transpose these essential items of information from the shippers ' papers.

3. Acceptance of radioactive materials consignments

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exceeding the 50 transport index maximum per vehicle -

In many cases carriers either do not appear to be aware of this limitation or fail to follow it. Concurrent with this requirement, each of the carrier regulations contain a table which prescribes certain stowage distances and l in certain cases stowage times for accumulations of radio- l active materials packages, based on the total transport l index. These stowage controls are intended to. provide the necessary segregation distance of packages from areas occupied by persons or photographic film. An increased  ;

effort is needed by carriers to more completely train l and educate their personnel in this requirement. l l

4 Failure to placard transport vehicles - For any rail or highway vehicle transporting any quantity of radio-active materials packages bearing the radioactive YELLOW-III label, the carrier is required to display the appro-priate placard. In many cases, the carrier has been ,

noted to fail to do this. Intentional failure to placard vehicles so as to avoid certain bridge, turnpike, tunnel, or other travel restrictions is a very serious offense.

VI. IAEA REGULATIONS The IAEA (International Atomic Energy Agency) " Regulations for the Safe Transport of Radioactive Materials, Safety Series No. 6, 1967 Edition," have now been accepted and adopted either wholly or in part by most nations as a standard for both national and international regulations. The DOT regula-tions were almost completely revised as of January 1, 1969 to achieve a substantial conformity with the IAEA Standards.

During February 1970, the IAEA convened a panel of experts from its member countries, for the purpose of considering proposed changes to the IAEA regulations. These proposed changes had been submitted in advance of the panel by each member country. As a result of that panel, three drafts of comprehensive revisions to Safety Series No. 6 were subsequently prepared. The third revised draft was submitted to each IAEA member country and various international organizations in December 1970. Official comments on it were then submitted to IAEA by June 1, 1971. la the USA, opportunity for public comment was afforded. (Federal Register Vol. 36, No. 18, January 27, 1971.) Another meeting of the review panel was

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35 then convened in October of 1971 to finalize the revisions.

The IAEA regulations in Safety Series No. 6 were revised in 1973.*

A significant number of changes were made in the 1973 ravised IaEA regulations. Many of these are concerned with the administrative approval requirements by the national

" competent authority" with respect to package, shipment, and special form approvals, as well as approval of "special form" designs and requirements for notification of certain types of shipments. A few of the other more significant changes include:

1. Toxicity Groups - Transport Groups I through VII will be eliminated, and instead a table will specify for each radionuclide a quantity A1 (maximum quantity of special form material in a Type A package), and a quantity A2 (the maximum quantity of non-special form material in a Type A package). Except for certain arbitrary upper limits, the Al value is based on the external radiation level if the contents were to escape from the package and A2 is based on the hazard of inhalation or ingestion (except where external radiation is more restrictive, in which case A2 will equal A 1 ).

The current " transport group" system places limits on the most restrictive radionuclide in the particular D group. The new system will effectively allow more quantity in a Type A package, for most radionuclides, but in some cases cause a reduction because of some change in the criteria used for establishing the values.

2. Transport Index - The point of measurement is changed from one meter from the center of the package to one meter from the surface of the package.

3. LSA Limit for Tritiated Water - The maximum activity of tritium in tritiated water to qualify as a low specific activity material was raised from five to 10 curies per liter.

4. Containment Standards for Packages - The present IAEA regulations specify "no loss or dispersal" and

" leak tightness" of packages even under accident con-ditions, except for large sources utilizing liquid coolant as a primary heat transfer medium. Recognizing that "zero loss" is technically unattainabic and that uncertainty now exists regarding the required degree of leak tightness, the Panel accepted a proposal to quantify containment standards in terms of release of activity, expressed as submultiples of'A2 With these for the Fafe Transport of Radioactive Materials, Dr" Regulations 1973 Revised Edition" Safety Feries No. 6, IAEA, Vienna, Austria. Available as document STI/ PUP /323 from Uniput, Inc.,

P. D. Box 433, Nev York, New York 10016

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limits it is then necessary to derive corresponding material Icakage rates and possibly to design enginect-ing tests for detecting these infinitely small allowabic material leakages.

5. Change in Radiation Level Criteria for Labels -

Packages which now bear a Radioactive-Yellow I: category label, indicating a maximum of 10 mrem /hr at the surface and 0.5 mrem /hr at one meter, are permitted IcVels of 50 mrem /hr at the surface and one mrem /hr at one meter from the surface. This change has been adopted into U.S. regulations (see Docket IIM-112) .

It is anticipated that proposed rule making to the DOT will be issued in late 1977, so as to bring the USA regulations as close in conformity to the international standards as possibic, hopefully by mid-1978.

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44g6 vu. RADI0 ACTIVE MATERIALS DEFINITIONS l i

The following definitions are derived from the Code of Pederal Regulations Title 49 - l Transportation Part 173.389. I PISSILE CIASSES - Ihe groupings into which radioactive material packages are classified according to the controle needed to provide nuclear criticality safety during transportation. (173.389(a)(1)-(3))-

PISSILE MATERIAL - Plutontua-238, plutonium-239, plutontua-241, uranium-233, uranium-235, I or any material containing any of the foregoing. (173.389(s) and 173.396(a)) l IARCE QUANTITT RADIOACTIVE MATERIALS - A quantity the aggregate radioactivity of which )

exceeds tnac specified in Part 173.389(b). (Large quantities are quantities exceeding j a Type B quantity, and also are sometimes refarred to as "large source s . "

l SMALL QUANTITY RADI0 ACTIVE MATERIALS - A quantity of radioactivity which does not exceed the limits specified in Part 173.391(a). Small quantities and certain radioactive i devices 173.391(b), are exempt from specification packaging, marking and labeling requirements, but still are subject to certain requirements, such as shipping paper requirements. j LOW SPECIPIC ACTIVITY MATERIAL - Material in which the activity is essentially uniformly distributed and in which the estimated average concentration per gram of contents does nor exceed the specifications of Part 173.389 (c).

SPECIAL P PORM RADIOACTIVE MATERIALS - Those materials which, if released from package, alght present some direct radiation hazard but would present little hasard due to

} radiotoxicity and little possibility of contamination. (173.389(3))

NORMAL PORM RADICACTIVE MATERIALS - Those materials which do not meet the requirements of Special Para Radioactive Materials. Normal form radioactive materials are grouped into " transport groups." (173.389(d))

TRANSPORT CROUP - Any one of seven groups into which normal form radionuclides are classified according to their radiotoxicity and their relative potential hazard in transportation.

(273.389(h))

TRANSPORT INDEI - A number placed on a package of "Tellow Label" radioactive materials by the shipper to denote the degree of control to be excercised by the carrier, i.e.,

the number of yellow labeled packages which may be placed in a single vehicle or storage location. The transport index is actually the measured dose rate of radiation at three feet from the surface of the package. (173.389(1))

TTPE "A" PACKACING - Packaging which is designed in accordance with the general packaging requirements of Parts 173.24 and 173.393 and which is adequate to prevent the loss or dispersal of the radioactive contents and to retain the efficiency of its radiation shield 1= properties if the package is subjected to the test prescribed in Pa.t 173.39 stb) (Normal conditions of transport). (173.389(j)

TYPE "A" QUAfrrITY RADI0 ACTIVE MATERIAL - That material which may be transported in Type "A" Packaging. (173.389(1))

TYPE "B" PACKACING - Packaging which meets the standards for Type "A" Packaging, and in addition, meets the standards fcr the hypothetical accident conditions of transport as prescribed in Part 173.398 (c) . (173. 389(k))

TYPE "B" QUANTITY RADI0 ACTIVE MATERIAL - That material which may be transported in Type "B" Packaging. (173.398(1))

The following definitions, though not derived from the Code of Pederal Regulations.

Title 49, are held as generally accepted meanings of the terms listed.

g AI.PRA PARTICLES - One of the three priesty forms of radioactive emissions from radioactive I f atoms. Alpha Particles are positively charged particles emitted from the nucleus of atoms having a mass and charge equal to the nucleus of a helium aton (2 protons + 2

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neutrons). Alpha Particles have very little penetrating ability and therefore are chiefly internal radiation hasards. They travel very short distances in air and are shielded very easily.

SITA PARTICLES - One of three primary forms of radioactive estestone f rom radioactive atoms. Seta Particles are negatively charged particles emitted from the nucleus of an stos and have a mass and charge equal to that of an electron. They travel greater distances in air than alpha particles, have an intermediate penetrating ability, but still are relatively easily shielded.

CAMA RATS- One of the three primary forms of radioactive emiselona f rom radioactive atoma.

Game Raye are not particulate (as opposed to alpha and beta particles) but are short wave length electromagnette radiations from the nucleus of radioactive atoms. Except for their origin (the nucleus of the atom rather than the outer shell) they are identical in characteristice to I-raya. Casmia Raye are the acet penetrating form of radiation and travel great distances in air. They require heavy shielding materiale such as lead to attenuate the radiation.

CURIE An expreselon of the quantity of radiation in torna of the number of atoms which disintegrate (decay) per second. A curie (C1) is that quantity of radioactive material which decaye each that 37 billion atome dietategrate per second. One thousandth of a cutie is a at111 curie (aci).

RADIATION LFVEL - A term somettaea used instead of radiation " dose rate." It generally refers to the effect of radiation on matter, that is, the energy imparted to and absorbed by matter due to radioactive saiselone per unit of time.

MILLIREM -One-one thousandth of a Res. The tem fa a unit somattaea used to express radiation level or does rateTaillites per hour). Technically speaking, the rea is an espression of radiation level or does rate which considere the ef fect oI~the radiation on persons. Do not confuse millites with curie.

INCAPSULATION - A tera used to denote en additional fabrication technique of ten used in preparation of radiation sources, wherein the beste material la physically placed within osaled, high physical integrity espeules or envelopes to provide further assurance that in the event a package breaks and the capsule escapes, there would be little poet sbility of a apread of particulate contanination.

WUCLEAR CRITICALITT - This tara denotes the occurence of an accidental chain reaction with fissile radioactive materiale. The purpose of the Fissile Classes to to prevent the occurence of a nuclear criticality during the transport of Fissile Materiale.

(Controlled nuclear criticality le the objective within a nuclear power reactor)

RADIO!$OTO?E AND RADIONUCLIDE - For the purpose of transportation, these terme are synonymous with " Radioactive Materials."

RAD 1070XICITT - A term used to denote the relative hasards of the various radionuclides, that is, their internal radioactive effect within the body.

gWIFE gAMPLE - A test for loose or removable radioactive contamination on surfaces (also seastimes referred to se a "emear" test).

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39 l>VIII. REFERENCES The following publications relating to transportation of rcdioactive materials are listed herein, as valuable and useful rsference sources of information to supplement this review.

1 " Summary of Federal Reulations for Packaging and Transportation of Radioactive Materials, " February, 1971, Report No. BRH/DMRE 71-1, prepared and published by the U. S. Department of Health, Education, and Welfare, Rockvil.'.e, Maryland.

Availability: National Technical Information Service Springfield, Virginia

2. IAEA " Regulations for the Safe Transportation of Radioactive Materials, Safety Series No. 6, 1973 Edition, " International Atomic Energy Agency, Vienna.

Availability: Unipub, Inc.

Post Office Box 433 New York, New York 10016

3. Book, "The Safe Transport of Radioactive Materials,"

edited by R. Gibson, 1966.

D Availability: Pergamon Press, Inc 44-01 21st Street Long Island City, New York 11101

4. Brochure, " Shipping Radioactive Materials," prepared and published by, and available from the Bechtel Corporation, 50 Beale Street, San Francisco, California.

5. Published proceedings of four international symposia on Packaging and Transportation of Radioactive Material, as follows:

First Symposium - Albuquerque, N. M. (1965),

Report No. SC-RR-65-98 Second Symposium - Gatlinburg, Tenn. (1968),

Report No. CONF-681001 Third Symposium - Richland, Washington (1971) ,

in three volumes; )

Vol. 1: Report No. CONF-710801 l (Vol. 1)

Vol. 2: Report No. CONF-710801 (Vol. 2)

Vol. 3: Report No. BNWL-SA-3906 I

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Pourth Symposium - Miami Beach, Florida, in three volumes, Report No.

CONF-740901-P1 through P3

6. " Summary Report of AEC Symposium on Packaging and Regulatory Standards for Shipping Radioactive Materials," held in Germantown, Maryland, December 3-5, 1962, Report No. TID-7651.

Availability: National Technical Information Service Springfield, Virginia 22151

7. " Radiological Emergency Procedures for the Non-Specialist," January 1969, a pamphlet published by the USAEC for the Interagency Committee on Radiological Assistance.

Availability: Superintendent of Documents U. S. Government Printing Office Washington, DC 20402

8. " Radiological Emergency Operations-Instruction Manual," and handbook prepared by the USAEC, Report l No. TID-24918.

Availability: National Technical Information Service Springfield, Virgina 22151

9. " Radiological Emergency Operations-Students Manual,"

a handbook prepared by the USAEC, Report No. TID-24918.

Availability: National Technical Informatio.1 Service Springfield, Virginia 22151

10. " Environmental Survey of Transportation of Radioactive Materials To and From Nuclear Power Plants", U.S.

Atomic Energy Commission (NRC), Wash-1238, December 1972

11. " Transportation Of Radioactive Material In the Western States", A report by the Western Interstate Nuclear Board, P. O. BOX 15038, Lakeswood, Colorado March 1974

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12. " Draft Environmental Impact Statements on Transportation of Radioactive Materials by Air and Other Modes" U. S. Nuclear Regulatory Commission, Office of Standard Development, March 1976

13. " Survey of Radioactive Material Shipment In the United States", BNWL-1972, Battele, Pacfic Northwest Laboratories, Richland, Washington.

14. " Evaluation of Radiation Emergencies and Accidents-Selected Criteria and Data" Technical Report Series No. 152, IAEA, Vienna, Austria 1974

15. " Certification of ERDA Contractors' Packaging With Respect to Compliance with DOT Specification 7A Perform-ance Requirements" - Two reports by Mound Laboratory, Mensanto Research Corporation, as follows:

Phase II Summary Report - June 12, 1975, MLM 2228 Phase II Summary Report (Supplement No. 1) - April 15, 1976, MLM 2228 (suppl. 1)

Availability: National Technical Information Service Springfield, Virginia 22151 I

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