Shipment

1
Shipment Receipt of Radioactive Materials

• By
• Mike Zittle
• Health Physicist

2
Why are You Here?

• Its REQUIRED!

3
DOT Training Requirements

• Subpart H - Training (49 CFR 172.700)
• Requirements - 49 CFR 172.704(a)
• General Awareness / Familiarization - THIS
• To identify hazardous materials
• Function - Specific Training
• Applicable to functions performed
• i.e. Generator Shipments - revised procedure
• Safety Training - HAZWOPER covers this
• Emergency Response, etc.
• Additional DOT Training Requirements MAY apply -
  Modal Specific Training

4
General Awareness / Familiarization49 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?

5
Function - Specific Training49 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

6
Safety Training49 CFR 172.704(a)

• Emergency Response information
• Measures to protect the employee
• Methods and procedures to prevent accidents
• HAZWOPER Training usually satisfies this
  requirement

7
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

8
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)

9
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

10
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 Employees name, training date, training
  materials (or material location), name and
  address of trainer, and certification of training

11
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

12
The Goal of this Training Class
13
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

14
Outline

• Applicability
• NRC Regulations
• DOT Regulations
• Training Regulations
• Package Receiving / Inspection
• Safety Training / Emergency Response

15
Applicability of DOT HazMat Regulations
16
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

17
NRC Regulations
18
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

19
DOT Regulations
20
DOT Regulations49 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

21
Exemption for Low-Level Materials 10 CFR 71.10

• Regulations do not apply to materials with a
  specific activity lt / 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.

22
Steps to Understanding DOT Regulations

• Classification
• Packaging
• Labeling
• Radiation Limits
• Marking
• Shipping Papers
• Placarding
• Conveyance

23
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!

24
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

25
DOT Classification
26
Classification of RAM - Different Levels of DOT
Requirements

• Exemptions
• Excepted (Limited) Quantities
• Special / Normal Form
• Type A Quantities
• Type B Quantities
• LSA, SCO, Empty

27
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

28
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)

29
DOT Exemptions

• lt / 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)

30
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

31
Classification as Normal Form

• 49 CFR 173.403
• Anything which is does not qualify as Special
  Form
• Can be solid, liquid, or gaseous

32
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

33
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

34
Special Classifications

• Excepted Quantities
• Empty
• LSA
• SCO

35
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

36
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

37
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

38
Review of Classifications

• Exempt - not considered radioactive (for DOT
  purposes) - lt 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

39
Transportation Activity Spectrum
40
General Requirements
41
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
  gt 10 may not be shipped by aircraft

42
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)

43
Contamination Control49 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

44
Contamination Limits - Table 11(49 CFR 173.443)
Exclusive Use Shipments have many more
Contamination Control Requirements
45
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

46
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

47
Packages
48
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.

49
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

50
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

51
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

52
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

53
Labeling
54
LabelingSurface 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

55
Labeling
56
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)

57
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)

58
Marking
59
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

60
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

61
Shipping Papers
62
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)

63
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

64
Proper Shipping Name, Hazard Class, ID Number
Domestic49 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

65
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

66
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

67
Shipping Papers for a Type A Shipment

• Shippers 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

68
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.

69
Emergency Response Information
70
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

71
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.

72
Emergency Response Information

• Maintenance of information
• Carriers
• information must be immediately accessible to
  pilots, drivers, etc.
• Drivers (are supposed) to carry shipping papers
  and emergency response information in the
  drivers 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

73
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

74
Placarding
75
Placarding49 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

76
Special Classifications
77
Excepted Activity Limits - Table 7 49 CFR 173.425
78
Requirements for Excepted Package - Limited
Quantity

• Table 7 - Activity Limits for Limited Quantities,
  Instruments, and Articles
• Activity Limits lt Table 7 - 49 CFR 173.425
• Package meets general design requirements - 49
  CFR 173.410
• Surface Radiation Levels lt 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

79
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

80
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

81
Excepted Package - Instrument or Article - 49 CFR
173.424

• Same requirements as for LQ Materials
• Dose rate from unshielded item must be lt 10
  mrem/hr at 10 cm
• If shipped Exclusive Use, does rate from the
  surface of the package must be lt 2 mrem/hr

82
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

83
Activity limits for Limited Quantity Materials
Packages, Other Liquids - 10-4 A2
84
Activity limits for Limited Quantity Materials
Packages, Solids, Normal Form - 10-3 A2
85
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

86
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 lt0.5 mrem / hr
• Outside surface contamination limits met
• 49 CFR 173.443(a)
• Package contains lt15 g U-235

87
Empty Class 7 Materials

• Package unimpaired and securely closed
• Internal contamination lt100 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)

88
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.

89
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.

90
Requirements for LSA and SCO49 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

91
Conveyance
92
Passenger Aircraft

• Radioactive Material on passenger aircraft must
  be for research or medical use
• 49 CFR 173.448(f)
• Transport index must be lt3.0 if passengers are on
  board
• Type B Packages are not allowed on passenger
  aircraft
• Separation Distances apply
• Cargo Aircraft have fewer restrictions

93
Carriage by Public Highway
94
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

95
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

96
Shipping Papers49 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

97
Contamination of Vehicles49 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

98
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.

99
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

100
Receiving and Opening Radioactive Material
Packages
101
Receiving Packages

• When receiving packages containing materials in
  excess of Type A Quantity
• make arrangements to receive package when offered
  for delivery
• When notified its at the carriers 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

102
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

103
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

104
Safety Training49 CFR 172.704(a)

• Emergency Response
• Measures to protect the employee
• Methods for avoiding accidents

105
Emergency Response

• Notify final carrier and NRC if
• Radiation level greater than 200 mrem/hr on
  package surface
• Contamination - averaged over 300 cm2
• gt22 dpm / cm2 beta/gamma, low toxicity alphas
• gt2.2 dpm / cm2 other alphas

106
Immediate Notification of DOT Required by
Carrier49 CFR 171.15 and .16

• Persons killed
• Injuries requiring hospitalization
• Carrier or other property damage gt50,000
• Evacuation of general public gt 1 hour
• Major transportation artery shutdown for gt 1 hour
• Flight pattern or routine of aircraft is altered
• Fire, breakage, spillage or suspected radioactive
  contamination involving Class 7 shipment

107
Immediate Notification of DOT Required by
Carrier49 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)

108
Immediate Notification of DOT Required by
Carrier49 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

109
Measures to Protect the Employee

• Training (understand radiation safety)
• Protective Clothing
• Survey Meter (available, operational)
• Procedures
• Contamination Check
• ALARA
• Time, Distance, Shielding

110
Methods for Avoiding Accidents

• Training
• Follow Procedures
• Check for Contamination
• Ask questions, if unsure
• Notify if ANYTHING unusual is noted

111
DOT Fines
112
DOT Fines

• 9,800 - Failure to brace packages Failure to
  provide employee training Inaccurate hazard
  labels No shippers 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

113
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

114
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

115
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