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

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

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

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.

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.

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.

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

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

49 CFR 172.200 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

49 CFR 172.300 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

49 CFR 172.400 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

Radioactive White I Label Package surface ≤ 0.5 mRem/hr. (0.005 mSv/hr.) 1 meter from the package <0.05 mRem/hr. (0.0005 mSv/hr.)

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.)

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

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

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 173.453) 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

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)

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 = 100.0 mRem/hr. 1 meter dose rate = 12.5 mRem/hr.

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

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

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

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

Labeling Interactive – Package #5 Surface dose rate = 100.0 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

49 CFR 172.500 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 173.427 (b) (4) and (5) or (c)

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

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

49 CFR 172.800 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

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

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” (173.423)

49 CFR 173-Subpart I Progressive Regulation of Radioactive Materials 173.436 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 (173.421) Instruments or Articles (173.424) Empty Packaging (173.428) Articles manufactured from natural or depleted uranium or natural thorium (173.426)

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)

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?

Solution – Is It Regulated Look up exempt values for H-3 in 173.436 Consignment Limit = 2.7 x 10-2 Ci = 27 mCi Activity Concentration for Exempt Material Limits = 2.7 x 10-5 Ci/gm. = 0.027 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. = 0.001 mCi/gm. Compare actual specific activity to the Activity Concentration for Exempt Materials Limit 0.001 mCi/gm. < 0.027 mCi/gm. NOT REGULATED SINCE DID NOT EXCEED BOTH LIMITS

Unity Equation Sum of Fractions Subpart I uses several tables which list radionuclide limits for: Regulation as radioactive material (173.436) Limited Quantity and Instrument or Article limits (Table 4 173.425) Type A package limits (173.435) LSA Limits (173.403 Definitions and 173.435) 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

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?

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 173.435 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 = 0.49 + 0.04 + 0.15 = 0.68 <1.0 May ship as Type A

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 = 0.037 TBq = 37,000 MBq 1 mCi = 0.000037 TBq = 37 MBq 1 µCi = 0.037 MBq = 37,000 Bq Radiation dose rates are reported in Sieverts 1 mRem = 0.01 mSv 1 Rem = 0.01 Sv

Radioactive Material Packaging 173.410 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

Radioactive Material Packaging 173.411 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 173.412 Type A design requirements 173.427 Table 6 provides IP package selection guidance

Radioactive Material Packaging Type – A Packaging 173.412, 173.465, and 173.466 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

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

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 173.469 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

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

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.

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

DOT Segregation Table for Hazardous Materials 49 CFR 177.848 Segregation DOT Segregation Table for Hazardous Materials Class or division Notes 1.1 1.2 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.

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…

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

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.

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.