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
o DOT in 49 CFR 172 Subpart H – Training
o IATA in Section 1.5 Training Requirements
o 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:
o Fines
o Suspension of the ability to ship
o 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:
o Loads, unloads, or handles radioactive material
o Designs, manufactures, fabricates, inspects, marks, maintains,
reconditions, repairs, or tests a package that is used for
transporting radioactive material.
o Prepares radioactive material for transport
o Is responsible for the safety of transporting radioactive
materials
o Operates a vehicle used to transport radioactive materials
WHERE DO I START?
• USE THE REGULATIONS
o 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.
o 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:
o Table 1 lists chemicals and EPA RCRA regulated waste
codes
o Table 2 lists radionuclides
• When shipping radioactive material we must consider
both tables since:
o Radioactive material may be incorporated in or on a
chemical substance
o 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
o Radioactive White I – low radiation levels, near
background
o Radioactive Yellow II – moderate radiation levels
o 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?
1. Surface dose rate = 0.4 mRem/hr. 1 meter dose rate = 0.07
mRem/hr.
2. Surface dose rate = 0.2 mRem/hr. 1 meter dose rate = 0.03
mRem/hr.
3. Surface dose rate = 40.0 mRem/hr. 1 meter dose rate = 1.2
mRem/hr.
4. Surface dose rate = 12.0 mRem/hr. 1 meter dose rate = 0.7
mRem/hr.
5. 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
o 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:
oGeneral awareness/familiarization training
oFunction specific training
oSafety training
oSecurity awareness training
oIn-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)
Radionuclide
Activity (Ci)
Am-241
16
Am-241/Be
16
Cf-252
5.4
Cm-244
14
Co-60
8.1
Cs-137
27
Gd-153
270
Ir-192
22
Pu-238
16
Pu-239/Be
16
Pm-147
11,000
Ra-226
11
Se-75
54
Sr-90 (Yt-90)
270
Tm-170
5,400
Yb-169
81
49 CFR 173.2a
Hazard Precedence
• Radioactive material that exhibits additional
hazards will be classified Radioactive Material
oRadioactive 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:
o Limited Quantities (173.421)
o Instruments or Articles (173.424)
o Empty Packaging (173.428)
o 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
o 250 lbs. x 454 gm./lb. = 113,500 gm.
o 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:
o Regulation as radioactive material (173.436)
o Limited Quantity and Instrument or Article limits (Table 4
173.425)
o Type A package limits (173.435)
o 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)?
o 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
o 1 Ci = 0.037 TBq = 37,000 MBq
o 1 mCi = 0.000037 TBq = 37 MBq
o 1 µCi = 0.037 MBq = 37,000 Bq
• Radiation dose rates are reported in Sieverts
o 1 mRem = 0.01 mSv
o 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:
o Water spray
o Drop test (4 feet)
o Penetration test (3.3 feet)
o Compression test
• Liquids & gasses require additional testing:
o Drop test (30 feet)
o 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
o 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.
o Special Form material should have certification documentation
showing compliance with performance criteria in 173.469
o A1 limits may be higher than A2 limits
• A2 is the Type A limit for “Normal Form” radioactive material
o Normal Form is radioactive material that is not Special Form
o Most radioactive material is Normal Form
o 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
o Open Vehicle – 200 mRem/hr. surface, no TI limit
o Closed Vehicle – 1,000 mRem/hr. surface, no TI Limit
• Vehicle Limits
o Surface – 200 mRem/hr.
o 2 meters from vehicle surface – 10 mRem/hr.
o 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:
oBeta gamma and low toxicity alpha = 2,200
dpm/100cm²
oAlpha = 220 dpm/100cm²
49 CFR 177.848
Segregation
DOT Segregation Table for Hazardous
Materials
6.1
2.3
gas
1.1
Zone Zone
Notes 1.2 1.3 1.4 1.5 1.6 2.1 2.2
A
B
Class or division
Radioactive
materials
2.3
gas
7
X
X
3
4.1 4.2 4.3 5.1
5.2
liquid
PG I
Zone
A
O
• Radioactive Material is compatible with most
hazardous materials.
8
7
liquido
nly
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.