1. RADIOACTIVE MATERIALS WHAT EVERY INSTRUCTOR NEEDS TO KNOW
Presented by:
Andy Armbrust, V.P.
Ecology Services, Inc.
10427 Hickory Path Way
Knoxville, TN 37922

2. WHY CONDUCT TRAINING? Required by regulatory agencies
DOT in 49 CFR 172 Subpart H – Training
IATA in Section 1.5 Training Requirements
Training is generally required as a condition of being issued a Radioactive Materials License by the NRC or an Agreement State
Properly trained personnel will help to ensure a correct outcome
Failure to conduct training will result in severe regulatory consequences including:
Fines
Suspension of the ability to ship
Criminal charges

3. WHO NEEDS TRAINING?
Anyone who offers for transport, accepts for transportation, transfers or otherwise handles radioactive materials during transportation.
The following functions are considered to be hazmat related and anyone performing must be trained:
Loads, unloads, or handles radioactive material
Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package that is used for transporting radioactive material.
Prepares radioactive material for transport
Is responsible for the safety of transporting radioactive materials
Operates a vehicle used to transport radioactive materials

4. WHERE DO I START? USE THE REGULATIONS
Power Point presentations may reinforce what is being taught but every student should become familiar with the regulations, how they are arranged, how to navigate through them.
We do not use Power Point when shipping radioactive or other hazardous materials. We should always use a current copy of the applicable regulations while training shippers.

5. 49 CFR Hazardous Materials Transportation Regulations
Part 172 – Contains the Hazardous Materials Table, Special Provisions, Hazardous Substances, Marine Pollutants, Shipping Paper, Marking, Labeling, Placarding, Emergency Response, Training, and Security requirements.
Part 173 – Contains Subpart – I which addresses specific requirements for shipping radioactive materials.
Part 174 – Modal specific requirements for rail
Part 175 – Modal specific requirements for air
Part 176 – Modal specific requirements for vessels
Part 177 – Modal specific requirements for highway
Radioactive materials shipper training will generally focus the most attention on 49 CFR parts 172 and 173.

6. 49 CFR Part 172
The instructor should ensure that students clearly understand that Part 172 contains general requirements that apply to the shipment of all hazardous materials including radioactive materials.
Unless a specific exception is offered in Part 173 the requirements of Part 172 must be followed.

7. 49 CFR 172.101 Hazardous Materials Table
The Hazardous Materials Table provides a listing of the hazardous materials regulated by DOT and guides the user to the appropriate regulations including:
Establishes proper shipping name and UN ID Number
Specifies hazardous materials labeling and placarding
Lists any special provisions that may apply
Guides the user to any exceptions that may be available
Guides the user to specific packaging and shipping requirements for either bulk or non-bulk packaging
Establishes quantity limitations for shipments by air
Provides vessel stowage requirements for water shipments

8. HAZARDOUS SUBSTANCES (RQ VALUES)
Appendix A to the Hazardous Materials Table lists Hazardous Substances (RQ).
Appendix A contains two tables:
Table 1 lists chemicals and EPA RCRA regulated waste codes
Table 2 lists radionuclides
When shipping radioactive material we must consider both tables since:
Radioactive material may be incorporated in or on a chemical substance
Radioactive material will have one or more radionuclides listed in Table 2

9. 49 CFR Shipping Papers
Shipping papers for radioactive materials must contain:
Proper shipping name and UN ID number
Hazard class
Any subsidiary hazard class(s)
Total quantity and number and type of packages
Each radionuclide
Physical and chemical form
Activity contained in each package in SI units
Category of label applied (Radioactive White I, Radioactive Yellow II, or Radioactive Yellow III)
If the shipment is required to be “Exclusive Use” must be so designated on the shipping papers
If the shipment is Highway Route Controlled Quantity the shipping papers will indicate HRCQ
If the shipment contains fissile radionuclides (U-233, U-235, Pu-239, Pu-241) the shipping paper will either list the Criticality Safety Index or “Fissile Excepted” as appropriate

10. 49 CFR MARKING
Radioactive materials packages will be marked with the following:
Proper shipping name and UN ID number
RQ (if applicable)
Consignee or consignor name & address (if transported by highway and will not transfer between carriers, not required)
Gross weight if >110 lbs.
Each Type A, Type B or IP 2 or IP 3 package must be marked with the package type and the international vehicle registration code for country of origin of its design
Each Type B package will be marked with an indestructible radiation trefoil symbol

11. 49 CFR Labeling
Must apply 2 labels on opposite sides of the package
Radioactive labels are selected based upon the radiation dose rate on the package surface and at one meter
Radioactive labels can visually indicate the relative radiation hazard to personnel who are handling packages
Radioactive White I – low radiation levels, near background
Radioactive Yellow II – moderate radiation levels
Radioactive Yellow III – higher radiation levels

12. Radioactive White I Label
Package surface ≤ 0.5 mRem/hr. (0.005 mSv/hr.)
1 meter from the package <0.05 mRem/hr. ( mSv/hr.)

13. Radioactive Yellow II Label
Package surface >0.5 mRem/hr. (0.005mSv/hr.) and ≤ 50 mRem/hr. (0.5 mSv/hr.)
1 meter from the package ≤1 mRem/hr. (0.01 mSv/hr.)

14. Radioactive Yellow III Label
Package surface
> 50 mRem/hr. (0.5mSv/hr.)
1 meter from the package
> 1 mRem/hr. (0.01 mSv/hr.)

15. Transport Index Transport Index = TI
Unit less number determined by obtaining the highest radiation level in mRem/hr. one meter from the package surface and rounding to the next tenth.
1.05 mRem/hr. = 1.1 TI

16. Radioactive Fissile Label
Only used if package contains fissile radionuclides – U-233, U-235, Pu-239, and Pu-241 greater than excepted values (49 CFR )
Must be used with the appropriate Radioactive W-I, Y-II, or Y-III label
Criticality Safety Index (CSI) is determined by following NRC guidance in 10 CFR 71

17. Empty Label Possibly the most improperly used hazmat label
Only used for empty radioactive material packages with residual internal contamination (up to 100 times the allowable exterior contamination level)

18. Interactive – Which Label Do I Use?
You are preparing several packages for shipment. The surface and 1 meter dose rates are listed below. What Radioactive label should be used?
Surface dose rate = 0.4 mRem/hr. 1 meter dose rate = 0.07 mRem/hr.
Surface dose rate = 0.2 mRem/hr. 1 meter dose rate = 0.03 mRem/hr.
Surface dose rate = 40.0 mRem/hr. 1 meter dose rate = 1.2 mRem/hr.
Surface dose rate = 12.0 mRem/hr. 1 meter dose rate = 0.7 mRem/hr.
Surface dose rate = mRem/hr. 1 meter dose rate = 12.5 mRem/hr.

19. Labeling Interactive – Package #1
Surface dose rate = 0.4 mRem/hr. = White I
1 meter dose rate = 0.07 mRem/hr. = Yellow II
Correct label is Radioactive Yellow II with a 0.1 TI

20. Labeling Interactive – Package #2
Surface dose rate = 0.2 mRem/hr. = White I
1 meter dose rate = 0.03 mRem/hr. = White I
Correct label is Radioactive I

21. Labeling Interactive – Package #3
Surface dose rate = 40.0 mRem/hr. = Yellow II
1 meter dose rate = 1.2 mRem/hr. = Yellow III
Correct label is Radioactive Yellow III with a 1.2 TI

22. Labeling Interactive – Package #4
Surface dose rate = 12.0 mRem/hr. = Yellow II
1 meter dose rate = 0.7 mRem/hr. = Yellow II
Correct Label is Radioactive Yellow II with a 0.7 TI

23. Labeling Interactive – Package #5
Surface dose rate = mRem/hr. = Yellow III
1 meter dose rate = 12.5 mRem/hr. = Yellow III
Correct label is Radioactive Yellow III with a 12.5 TI

24. 49 CFR Placarding
A vehicle transporting radioactive material must be placarded Radioactive if:
Any quantity of packages with Radioactive Yellow III labels.
Any quantity of Radioactive LSA or Radioactive SCO shipped under the provisions of 49 CFR (b) (4) and (5) or (c)

25. 49 CFR 172.600 Emergency Response Information
Required for any radioactive material that requires shipping papers
Radioactive Material Excepted Package does not require shipping papers
A copy of the appropriate ERG Guide may be used
Must also provide an emergency response telephone number that is staffed 24/7 by personnel knowledgeable of the material being shipped and can provide incident mitigation information

26. 49 CFR 172.700 Training Training includes:
General awareness/familiarization training
Function specific training
Safety training
Security awareness training
In-depth security training
Initial training required within 90 days of employment or job change
Recurrent training required every 3 years

27. 49 CFR Security Plan
A Security Plan is required for radioactive materials if:
Uranium hexafluoride requiring placarding
Highway Route Controlled Quantity 3,000 x’s A1 or A2 value or 27,000 curies
NRC Quantity of Concern

28. NRC Quantity of Concern
Radionuclide
Activity (Ci)
Am-241 16
Am-241/Be
Cf-252
5.4
Cm-244 14
Co-60
8.1
Cs-137 27
Gd-153
270
Ir-192 22
Pu-238
Pu-239/Be
Pm-147
11,000
Ra-226 11
Se-75 54
Sr-90 (Yt-90)
Tm-170
5,400
Yb-169 81

29. 49 CFR 173.2a Hazard Precedence
Radioactive material that exhibits additional hazards will be classified Radioactive Material
Radioactive Material Excepted Package – Limited Quantity of Material UN-2910 is the exception to this rule. If Radioactive Limited Quantity has additional hazards, the material will be packaged, marked, labeled, and shipped for the other hazard. The basic description on the shipping paper will be modified to include “Limited quantity radioactive material” ( )

30. 49 CFR 173-Subpart I Progressive Regulation of Radioactive Materials
Establishes the threshold at which DOT begins to regulate radioactive material
Must be in excess of BOTH the Activity Concentration for Exempt Material and the Activity Limit for Exempt Consignments to be regulated as radioactive material
In many cases a package that is not regulated as a radioactive material may have a measurable radiation dose rate
Radioactive material excepted package offers exceptions for low activity low hazard radioactive materials
Package dose rates must be <0.5 mRem/hr.
Exceptions for:
Limited Quantities ( )
Instruments or Articles ( )
Empty Packaging ( )
Articles manufactured from natural or depleted uranium or natural thorium ( )

31. 49 CFR 173-Subpart I Progressive Regulation of Radioactive Materials
Radioactive material Type–A must be packaged in containers that are certified to withstand normal transport conditions and are subject to all shipping paper, marking, labeling, placarding, and emergency response information requirements in 49 CFR 172
LSA and SCO have radioactivity distributed throughout. May be shipped in excess of Type-A limits and within the US may utilize an exception to packaging, marking, and labeling
Type-B has enough radioactivity to require packaging that can withstand accident conditions (Regulated by the NRC)

32. Interactive – Is It Regulated?
You need to ship 5 – 50 pound packages, each containing 25 mCi of H-3 (Tritium). Is this shipment regulated as radioactive material by the DOT?

33. Solution – Is It Regulated
Look up exempt values for H-3 in
Consignment Limit = 2.7 x 10-2 Ci = 27 mCi
Activity Concentration for Exempt Material Limits = x 10-5 Ci/gm. = mCi/gm.
Compare shipment actual values to DOT limits
Actual Consignment total activity = 125 mCi Limit = 27 mCi
To evaluate the Activity Concentration for Exempt Material limit we must determine the specific activity of the material by dividing the activity by its weight in grams
250 lbs. x 454 gm./lb. = 113,500 gm.
125 mCi/113,500 gm. = mCi/gm.
Compare actual specific activity to the Activity Concentration for Exempt Materials Limit mCi/gm. < mCi/gm.
NOT REGULATED SINCE DID NOT EXCEED BOTH LIMITS

34. Unity Equation Sum of Fractions
Subpart I uses several tables which list radionuclide limits for:
Regulation as radioactive material ( )
Limited Quantity and Instrument or Article limits (Table )
Type A package limits ( )
LSA Limits ( Definitions and )
If shipping a package with a single radionuclide you simply compare the actual activity to the appropriate limit.
If shipping multiple radionuclides you must use a unity equation to determine if the package total activity is below the limit.
Activity1/Limit1 + Activity2/Limit2 + Activity3/Limit3 = ≤1

35. Interactive – Sum of Fractions Calculation
You are preparing a package for shipment. It contains 3 vials of powdered radionuclides:
Ra-226 = 40.0 mCi
Pu-241 = 60.0 mCi
Am-241 = 4.0 mCi
Can this material be shipped as Radioactive Material, Type A Package?

36. Solution – Sum of Fractions
Is the material Special Form (A1) or Normal Form (A2)?
Normal Form (A2) dispersible powder
Look up A2 values in 49 CFR
Ra-226 = 8.1 x 10-2 Ci = 81.0 mCi
Pu-241 = 1.6 Ci = 1600 mCi
Am-241 = 2.7 x 10-2 Ci = 27 mCi
Set up unity equation dividing the actual activity by its respective limit:
40mCi/81mCi + 60mCi/1600mCi + 4mCi/27mCi =
= 0.68
<1.0 May ship as Type A

37. SI Units SI units are required on shipping papers and labels
May show traditional units in parenthesis after the SI unit
Activity is reported in Becquerels
1 Ci = TBq = 37,000 MBq
1 mCi = TBq = 37 MBq
1 µCi = MBq = 37,000 Bq
Radiation dose rates are reported in Sieverts
1 mRem = 0.01 mSv
1 Rem = 0.01 Sv

38. Radioactive Material Packaging
General Design Requirements
Basis for all radioactive materials packages
Replaces the older requirement for “strong tight package” with minimum performance criteria
Acceptable packaging for Limited Quantity, Instruments or Articles, LSA-I, SCO-1, or LSA/SCO exclusive use within the USA

39. Radioactive Material Packaging
Industrial Packaging
Industrial Packaging may only be used for LSA & SCO
IP-1 least stringent standard, must meet general design requirements. Replaces old references to ‘strong tight”
IP-2, must meet IP-1 standards and pass a drop and stacking test.
IP-3, must meet IP-1 & IP-2 standards as well as most Type A design requirements
Table 6 provides IP package selection guidance

40. Radioactive Material Packaging
Type – A Packaging , , and
Must be used to ship Radioactive Material Type-A Package
Designed to meet normal transport conditions
Testing includes:
Water spray
Drop test (4 feet)
Penetration test (3.3 feet)
Compression test
Liquids & gasses require additional testing:
Drop test (30 feet)
Penetration test (5.5 feet)
Type – A may also be used to ship Limited Quantity, Instruments or Articles, LSA, and SCO

41. Radioactive Material Packaging
Type – B Packaging
Must be used to ship Radioactive Material Type B
Certification of Type B packages done by NRC in the United States
Package design, testing, and certification is very expensive. Most Type B packages are reusable overpacks, many incorporate shielding
Designed to withstand hypothetical accident conditions

42. Which Do I Use? A1 or A2
A1 is the Type A limit for a “Special Form” radioactive material
Special Form is either a durable encapsulation or a single solid piece in which there is little risk of contamination being released from the item.
Special Form material should have certification documentation showing compliance with performance criteria in
A1 limits may be higher than A2 limits
A2 is the Type A limit for “Normal Form” radioactive material
Normal Form is radioactive material that is not Special Form
Most radioactive material is Normal Form
A2 limits may be the same as A1 limits or lower. A2 will never be higher than A1

43. Radiation Level Limits
Non-Exclusive Use
Container surface ≤200 mRem/hr.
Container TI ≤10
Total TI on the vehicle ≤50

44. Radiation Level Limits
Exclusive Use
Package Limits
Open Vehicle – 200 mRem/hr. surface, no TI limit
Closed Vehicle – 1,000 mRem/hr. surface, no TI Limit
Vehicle Limits
Surface – 200 mRem/hr.
2 meters from vehicle surface – 10 mRem/hr.
Occupied areas of vehicle cab – 2 mRem/hr.

45. Contamination Limits
Contamination is monitored by wiping an area of 300 cm² with an absorbent filter using moderate pressure and counting the filter using appropriate monitoring instrumentation.
DOT requires the use of a collection efficiency of 10%
Using a collection efficiency, the effective contamination limit for radioactive materials is:
Beta gamma and low toxicity alpha = 2,200 dpm/100cm²
Alpha = 220 dpm/100cm²

46. DOT Segregation Table for Hazardous Materials
49 CFR Segregation
DOT Segregation Table for Hazardous Materials
Class or division
Notes
1.3
1.4
1.5
1.6
2.1
2.2
2.3 gas Zone A
2.3 gas Zone B 3
4.1
4.2
4.3
5.1
5.2
6.1 liquid PG I Zone A 7
8 liquidonly
Radioactive materials X O
Radioactive Material is compatible with most hazardous materials.

47. DOT vs. ICAO ICAO requires training every 2 years, DOT every 3 years
ICAO establishes minimum instructor training requirements, DOT does not
Every package shipped by air must be marked with the shipper’s and receiver's name and address
ICAO requires the use of an excepted package label for any item shipped Radioactive Material Excepted Package…

48. DOT vs. ICAO
Dry Ice is regulated as a hazardous material by ICAO, not regulated by DOT if shipped by ground transport
DOT only allows radioactive material used in research or medical diagnosis or treatment on passenger aircraft
DOT will not allow a package with a TI greater than 3 on a passenger aircraft
DOT maintains restrictions on Plutonium shipped by air
ICAO recognizes LSA & SCO fissile; DOT does not allow LSA & SCO with fissile material above fissile excepted amounts
ICAO specifies requirements for Radioactive Material Type C Package, DOT does not

49. DOT vs. ICAO
Air shipments originating or ending in the United States must be compliant with 49 CFR requirements. ICAO regulations generally refer the user to Chapter 2 where country and carrier limitations are specified.

50. So, How Do I Stay Out of Trouble
Pay attention to your shipping papers
One of the first things that gets looked at is shipping papers. After the shipment is complete, you must retain a copy of the shipping paper for 2 years. Many compliance audits are only looking at records after the shipment has been completed.
Perform accurate radiation and contamination surveys
Radioactive materials licensees are required to perform radiological surveys upon receipt of radioactive material. If limits are exceeded they are required to make notification to their licensing agency (NRC or State) who in turn will notify DOT.
Ensure that package marking and labeling is consistent with shipping paper entries.
Ensure that placards are properly applied
Properly secure the shipment to prevent shifting during transport
Make everything neat. DOT does not require neat but human nature will cause an inspector to look harder at sloppy.