Presentation on theme: "RADIOACTIVE MATERIALS WHAT EVERY INSTRUCTOR NEEDS TO KNOW"— Presentation transcript:
1RADIOACTIVE MATERIALS WHAT EVERY INSTRUCTOR NEEDS TO KNOW Presented by:Andy Armbrust, V.P.Ecology Services, Inc.10427 Hickory Path WayKnoxville, TN 37922
2WHY CONDUCT TRAINING? Required by regulatory agencies DOT in 49 CFR 172 Subpart H – TrainingIATA in Section 1.5 Training RequirementsTraining is generally required as a condition of being issued a Radioactive Materials License by the NRC or an Agreement StateProperly trained personnel will help to ensure a correct outcomeFailure to conduct training will result in severe regulatory consequences including:FinesSuspension of the ability to shipCriminal charges
3WHO 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 materialDesigns, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package that is used for transporting radioactive material.Prepares radioactive material for transportIs responsible for the safety of transporting radioactive materialsOperates a vehicle used to transport radioactive materials
4WHERE 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.
549 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 railPart 175 – Modal specific requirements for airPart 176 – Modal specific requirements for vesselsPart 177 – Modal specific requirements for highwayRadioactive materials shipper training will generally focus the most attention on 49 CFR parts 172 and 173.
649 CFR Part 172The 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.
749 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 NumberSpecifies hazardous materials labeling and placardingLists any special provisions that may applyGuides the user to any exceptions that may be availableGuides the user to specific packaging and shipping requirements for either bulk or non-bulk packagingEstablishes quantity limitations for shipments by airProvides vessel stowage requirements for water shipments
8HAZARDOUS 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 codesTable 2 lists radionuclidesWhen shipping radioactive material we must consider both tables since:Radioactive material may be incorporated in or on a chemical substanceRadioactive material will have one or more radionuclides listed in Table 2
949 CFR Shipping PapersShipping papers for radioactive materials must contain:Proper shipping name and UN ID numberHazard classAny subsidiary hazard class(s)Total quantity and number and type of packagesEach radionuclidePhysical and chemical formActivity contained in each package in SI unitsCategory 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 papersIf the shipment is Highway Route Controlled Quantity the shipping papers will indicate HRCQIf 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
1049 CFR MARKINGRadioactive materials packages will be marked with the following:Proper shipping name and UN ID numberRQ (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 designEach Type B package will be marked with an indestructible radiation trefoil symbol
1149 CFR LabelingMust apply 2 labels on opposite sides of the packageRadioactive labels are selected based upon the radiation dose rate on the package surface and at one meterRadioactive labels can visually indicate the relative radiation hazard to personnel who are handling packagesRadioactive White I – low radiation levels, near backgroundRadioactive Yellow II – moderate radiation levelsRadioactive Yellow III – higher radiation levels
12Radioactive White I Label Package surface ≤ 0.5 mRem/hr. (0.005 mSv/hr.)1 meter from the package <0.05 mRem/hr. ( mSv/hr.)
13Radioactive 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.)
14Radioactive Yellow III Label Package surface> 50 mRem/hr. (0.5mSv/hr.)1 meter from the package> 1 mRem/hr. (0.01 mSv/hr.)
15Transport 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
16Radioactive 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 labelCriticality Safety Index (CSI) is determined by following NRC guidance in 10 CFR 71
17Empty 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)
18Interactive – 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.
19Labeling Interactive – Package #1 Surface dose rate = 0.4 mRem/hr. = White I1 meter dose rate = 0.07 mRem/hr. = Yellow IICorrect label is Radioactive Yellow II with a 0.1 TI
20Labeling Interactive – Package #2 Surface dose rate = 0.2 mRem/hr. = White I1 meter dose rate = 0.03 mRem/hr. = White ICorrect label is Radioactive I
21Labeling Interactive – Package #3 Surface dose rate = 40.0 mRem/hr. = Yellow II1 meter dose rate = 1.2 mRem/hr. = Yellow IIICorrect label is Radioactive Yellow III with a 1.2 TI
22Labeling Interactive – Package #4 Surface dose rate = 12.0 mRem/hr. = Yellow II1 meter dose rate = 0.7 mRem/hr. = Yellow IICorrect Label is Radioactive Yellow II with a 0.7 TI
23Labeling Interactive – Package #5 Surface dose rate = mRem/hr. = Yellow III1 meter dose rate = 12.5 mRem/hr. = Yellow IIICorrect label is Radioactive Yellow III with a 12.5 TI
2449 CFR PlacardingA 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)
2549 CFR 172.600 Emergency Response Information Required for any radioactive material that requires shipping papersRadioactive Material Excepted Package does not require shipping papersA copy of the appropriate ERG Guide may be usedMust 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
2649 CFR 172.700 Training Training includes: General awareness/familiarization trainingFunction specific trainingSafety trainingSecurity awareness trainingIn-depth security trainingInitial training required within 90 days of employment or job changeRecurrent training required every 3 years
2749 CFR Security PlanA Security Plan is required for radioactive materials if:Uranium hexafluoride requiring placardingHighway Route Controlled Quantity 3,000 x’s A1 or A2 value or 27,000 curiesNRC Quantity of Concern
28NRC Quantity of Concern RadionuclideActivity (Ci)Am-24116Am-241/BeCf-2525.4Cm-24414Co-608.1Cs-13727Gd-153270Ir-19222Pu-238Pu-239/BePm-14711,000Ra-22611Se-7554Sr-90 (Yt-90)Tm-1705,400Yb-16981
2949 CFR 173.2a Hazard Precedence Radioactive material that exhibits additional hazards will be classified Radioactive MaterialRadioactive 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” ( )
3049 CFR 173-Subpart I Progressive Regulation of Radioactive Materials Establishes the threshold at which DOT begins to regulate radioactive materialMust be in excess of BOTH the Activity Concentration for Exempt Material and the Activity Limit for Exempt Consignments to be regulated as radioactive materialIn many cases a package that is not regulated as a radioactive material may have a measurable radiation dose rateRadioactive material excepted package offers exceptions for low activity low hazard radioactive materialsPackage 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 ( )
3149 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 172LSA 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 labelingType-B has enough radioactivity to require packaging that can withstand accident conditions (Regulated by the NRC)
32Interactive – 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?
33Solution – Is It Regulated Look up exempt values for H-3 inConsignment Limit = 2.7 x 10-2 Ci = 27 mCiActivity Concentration for Exempt Material Limits = x 10-5 Ci/gm. = mCi/gm.Compare shipment actual values to DOT limitsActual Consignment total activity = 125 mCi Limit = 27 mCiTo 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 grams250 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
34Unity 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
35Interactive – Sum of Fractions Calculation You are preparing a package for shipment. It contains 3 vials of powdered radionuclides:Ra-226 = 40.0 mCiPu-241 = 60.0 mCiAm-241 = 4.0 mCiCan this material be shipped as Radioactive Material, Type A Package?
36Solution – Sum of Fractions Is the material Special Form (A1) or Normal Form (A2)?Normal Form (A2) dispersible powderLook up A2 values in 49 CFRRa-226 = 8.1 x 10-2 Ci = 81.0 mCiPu-241 = 1.6 Ci = 1600 mCiAm-241 = 2.7 x 10-2 Ci = 27 mCiSet 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
37SI Units SI units are required on shipping papers and labels May show traditional units in parenthesis after the SI unitActivity is reported in Becquerels1 Ci = TBq = 37,000 MBq1 mCi = TBq = 37 MBq1 µCi = MBq = 37,000 BqRadiation dose rates are reported in Sieverts1 mRem = 0.01 mSv1 Rem = 0.01 Sv
38Radioactive Material Packaging General Design RequirementsBasis for all radioactive materials packagesReplaces the older requirement for “strong tight package” with minimum performance criteriaAcceptable packaging for Limited Quantity, Instruments or Articles, LSA-I, SCO-1, or LSA/SCO exclusive use within the USA
39Radioactive Material Packaging Industrial PackagingIndustrial Packaging may only be used for LSA & SCOIP-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 requirementsTable 6 provides IP package selection guidance
40Radioactive Material Packaging Type – A Packaging , , andMust be used to ship Radioactive Material Type-A PackageDesigned to meet normal transport conditionsTesting includes:Water sprayDrop test (4 feet)Penetration test (3.3 feet)Compression testLiquids & 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
41Radioactive Material Packaging Type – B PackagingMust be used to ship Radioactive Material Type BCertification of Type B packages done by NRC in the United StatesPackage design, testing, and certification is very expensive. Most Type B packages are reusable overpacks, many incorporate shieldingDesigned to withstand hypothetical accident conditions
42Which Do I Use? A1 or A2A1 is the Type A limit for a “Special Form” radioactive materialSpecial 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 inA1 limits may be higher than A2 limitsA2 is the Type A limit for “Normal Form” radioactive materialNormal Form is radioactive material that is not Special FormMost radioactive material is Normal FormA2 limits may be the same as A1 limits or lower. A2 will never be higher than A1
43Radiation Level Limits Non-Exclusive UseContainer surface ≤200 mRem/hr.Container TI ≤10Total TI on the vehicle ≤50
44Radiation Level Limits Exclusive UsePackage LimitsOpen Vehicle – 200 mRem/hr. surface, no TI limitClosed Vehicle – 1,000 mRem/hr. surface, no TI LimitVehicle LimitsSurface – 200 mRem/hr.2 meters from vehicle surface – 10 mRem/hr.Occupied areas of vehicle cab – 2 mRem/hr.
45Contamination LimitsContamination 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/100cm²Alpha = 220 dpm/100cm²
46DOT Segregation Table for Hazardous Materials 49 CFR SegregationDOT Segregation Table for Hazardous MaterialsClass or divisionNotes18.104.22.168.22.214.171.124 gas Zone A2.3 gas Zone B126.96.36.199.15.26.1 liquid PG I Zone A78 liquidonlyRadioactive materialsXORadioactive Material is compatible with most hazardous materials.
47DOT vs. ICAO ICAO requires training every 2 years, DOT every 3 years ICAO establishes minimum instructor training requirements, DOT does notEvery package shipped by air must be marked with the shipper’s and receiver's name and addressICAO requires the use of an excepted package label for any item shipped Radioactive Material Excepted Package…
48DOT vs. ICAODry Ice is regulated as a hazardous material by ICAO, not regulated by DOT if shipped by ground transportDOT only allows radioactive material used in research or medical diagnosis or treatment on passenger aircraftDOT will not allow a package with a TI greater than 3 on a passenger aircraftDOT maintains restrictions on Plutonium shipped by airICAO recognizes LSA & SCO fissile; DOT does not allow LSA & SCO with fissile material above fissile excepted amountsICAO specifies requirements for Radioactive Material Type C Package, DOT does not
49DOT vs. ICAOAir 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.
50So, How Do I Stay Out of Trouble Pay attention to your shipping papersOne 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 surveysRadioactive 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 appliedProperly secure the shipment to prevent shifting during transportMake everything neat. DOT does not require neat but human nature will cause an inspector to look harder at sloppy.