Transportation of Radioactive Material by Air Contractors Transportation Management Association Conference Wednesday, July 8, 2015 Point Clear, Alabama Roy A. Parker, Ph.D. Radiation Physics Consultant

Air Carriers Transporting Radioactive Materials FedEx Express Domestic – Security Category 1 specified airports to airports only Canada – Door to door service International (except Canada) 023 Airport to airport only Possile to arrange door delivery in US and Canada

Air Carriers Transporting Radioactive Materials Fedex Ground Not ground division of FedEx Express RAM Excepted Packages and White I only FedEx Custom Critical Can handle Security Category 1 shipments coordinated with FedEx Express flights

Air Carriers Transporting Radioactive Materials United Parcel Service US Domestic Small Package System RAM Excepted Packages and White I only by contract No Fissile Material shipment with CSI > 0 US, Canada and Mexico – White I, Yellow II & Yellow III on UPS Freight, Air Services by prior arrangement Outside US & Canada RAM Excepted Packages on specified routes by prior arrangement.

Air Carriers Transporting Radioactive Materials American Airlines Only US passenger airline that I know Principally Mallinckrodt out of St. Louis Foreign Cargo Air Carriers Lufthansa Air France

Air Carriers Transporting Radioactive Materials Charter Air Carriers – DOT Special Permit AirNet (Canada Equivalent Level of Safety) Ameriflight (Canada Equivalent Level of Safety) Kalitta Charters Suburban Air Freight

Ground Carriers Transporting Radioactive Materials DOT Special Permit Operators Associated Couriers Del-Med FedEx Express (route specific) Medical Delivery Services Tradewind Enterprises

International Transport Standards and Regulations 49 CFR 171.12 and Part 171 Subpart C (171.22-171.26) 171.12 Canada TDG Regulations 171.22 Authorization and Conditions 171.23 ICAO, IMDG, TDG and IAEA Hazardous Substances RQ Radioactive Material: HRCQ, Fissile, Type A Quantities – 49 CFR

International Transport Standards and Regulations 171.23 ICAO, IMDG, TDG and IAEA Radioactive Materials (contd) Type A Package – Country of origin adopted IAEA TS-R-1 (1966) Type A Package – USA DOT 7A Type A Medical or Research TI Limit and Certification Definition of Radioactive Material 49 CFR Radioactive Material Excepted Packages

International Transport Standards and Regulations 171.24 ICAO Highway transport 49 CFR Placards – Yellow III packages 171.25 IMDG 171.26 IAEA Into (import), from (export) or through US

M Y T H

IATA Dangerous Goods Regulations - Misconceptions IATA 1.5.0.3 Two year training meaningless 49 CFR 172.704(c)(2) Three year training applies USA DOT 7A Type A (49 CFR 178.350) Type A Package Documentation must be maintained for one year after last shipment January 1, 2017 – Two year retention (49 CFR 173.415)

Chemical Form Shipping Paper Entry For normal form material the chemical form of the radionuclide is required as a shipping paper (Shipper’s Declaration for Dangerous Goods) entry Sealed sources Chemical form is not “metal” for example if it is metal encapsulated Chemical form is the chemical form of the radionuclide in the sealed source encapsulation

Don’t

Do RQ Sequence

Radioactive Materials and Subrisks Radioactive Material Excepted Package is a subrisk to another hazard class Radioactive material has another hazard class subrisk – Cargo Aircraft Only scenario (regulatory driven) Radioactive material has another hazard class subrisk – Passenger and CAO scenario (FedEx Express policy driven)

Radioactive Material Excepted Package is the Subrisk UN1993, Flammable liquid, n.o.s. (Ethanol and toluene mixture), Radioactive Material Excepted Package –Limited Quantity of Material, 3, II 1 plastic drum (1H2) x 250 mL 305 A130

Radioactive Material Excepted Package is the Subrisk Problem: What is the proper shipping name? Affects package marking Proper shipping name is defined as being listed in the Hazardous Material Table 49 CFR 172.101 Affects package checklist and training

Radioactive Material Excepted Package is the Subrisk Does not require Radioactive Material Excepted Package handling label.

Radioactive Material with Subrisk – Cargo Aircraft Only

Radioactive Material with Subrisk – Passenger Aircraft

FedEx Express IDG Label

FedEx Express IDG Label FX-03 Variation: Second Paragraph FedEx Express will not accept labelled radioactive material with a subsidiary of 1.4, 3, 4.1, 4.2, 4.3, 5.1, 5.2, 8 or 2.2 with a Cargo Aircraft Label unless the shipper has been preapproved. For approval contact Roy A. Parker, Ph.D., Radiation Physics Consultant, roy@royparker.org or 225-924-1473 You will be sent an IDG information packet.

Overpack Shipping Paper Format Issue

Overpack Shipping Paper Format Issue

Overpack Shipping Paper Format Issue 49 CFR 203(d)(4) and (5) that the category of label and transport index must be entered for each package. Overpack is not specifically addressed. Some regulators are interpreting the regulations as requiring label category and TI for each package plus the overpack.

Approved Software FX-18 Requires use of approved software for completion of Shipper’s Declaration for Dangerous Goods DOES NOT APPLY TO: Radioactive material shipments Originating in non-US locations FedEx International, FedEx International Express Freight (IXF), FedEx International Premium (IP1), [023 shipments]

Hand Written Shipper’s Declaration FX-12 Typed or Computer Generated Fields UN number, proper shipping name, hazard class or division, subsidiary risk or divisions packing group Physical and chemical form or special form, packaging type Packing instrctions Authorization Emergency telephone number

Hand Written Shipper’s Declaration FX-12 Permissible hand written radioactive material fields Actvity Category Label – White I, Yellow II, Yellow III Transport Index Package dimensions

Mixtures, Solutions and Individual Radioactive Sources For more than one radionuclide indicate Mixture or solution if applicate in Quantity and Type of Packing. FX-03 e.g. solid, salt mixture Gross activity of mixture or solution Indvidual Sources List activity of each source IATA 10.8.3.9.2 Step 7 Activity on label must correspond to declaration

RQ Radioactive Material Excepted Package Modified Shippers Declaration

RQ Radioactive Material Excepted Package RQ Marking Not required until July 13, 2015, but do so anyway to avoid having package bumped Dangerous Goods Declaration and Markings must be consistent.

Passenger and Cargo Aircraft Cargo Only Aircraft Not type of aircraft but package classification

Security Category 1 Radionuclide Curies Americium-241 2,000 Plutonium-238 Californium-252 500 Promethium-147 1,000,000 Curium-244 1,000 Radium-226 Cobalt-60 800 Selenium-75 5,000 Cesium-337 3,000 Strontium-90 Y(90) 30,000 Gadolinium-153 Thulium-170 500,000 Iridium-192 Yterbium-169 8,000

Security Category 1 FedEx Express can transport airport to airport where there is a customer service center at the airport ramps. It is not a violation of regulations for FedEx Express to transport Category 1 on the ground, but it is a violation for the shipper to offer an aggregate Category 1 total to FedEx Express.

Security Category 2 Radionuclide Curies Americium-241 16 Plutonium-238 Californium-252 5.4 Promethium-147 11,000 Curium-244 14 Radium-226 11 Cobalt-60 8.1 Selenium-75 54 Cesium-337 27 Strontium-90 Y(90) 270 Gadolinium-153 Thulium-170 5,400 Iridium-192 22 Yterbium-169 81

Security Category 2 FedEx Express can pick up and deliver Category 2 packages, because FedEx Express has an In Depth Security Program pursuant to 49 CFR 172.800.

Security Category 3 Radionuclide Curies Americium-241 2 Plutonium-238 Californium-252 5 Promethium-147 1,000 Curium-244 10 Radium-226 1 Cobalt-60 0.8 Selenium-75 Cesium-337 3 Strontium-90 Y(90) 0.3 Gadolinium-153 Thulium-170 500 Iridium-192 Ytterbium-169 8

Security Categories 3, 4 & 5 There are currently no transportation security requirements applicable to Categories 3, 4 and 5 Canada will impose transportation security requirements on Categories 3, 4 & 5 effective May 31, 2018.

NRC DOT 7A Type A Fissile Material Packages 49 CFR 173.417(a) recognizes certain fissile material shipments specified in10 CFR Part 71 Subpart C. Such shipments are not included in the IATA Dangerous Goods Regulations and FedEx Express training does not cover such shipments. A blanket approval letter for domestic shipments has been issued for these shipments by FedEx Express. This shipment approval letter must be completed and accompany all such shipments.

Recent Fissile Excepted Regulation Changes Recent changes in IATA no longer specify that “Fissile Excepted” be entered in the Packing Instruction column, but specify that the applicable IATA paragraph be referenced. Reference to a trade organization tariff is not an acceptable regulatory practice and will cause confusion. I recommend continued use of “Fissile Excepted” until this is resolved.

Hazmat Training 49 CFR 172 Subpart H Hazmat Employee Loads, unload, handles Tests, reconditions, repairs, modifies, marks, packaging Prepares hazardous material for transportation Operates a vehicle transporting hazardous materials

Training IATA 1.5.0.3 Recurrent training must be provided with 24 months of previous training – MYTH 49 CFR 172.704(c)(2) A hazmat employee must receive training … at least once every three years. FACT

Hazmat Training Certification and Instructor Employer certifies the training, not the course instructor No prerequisite qualifications for the course instructor Self training permitted Anyone may provide HazMat training provided it is complete, accurate and applicable to the HazMat operations being performed Roy A. Parker, Ph.D.

Hazmat Training 49 CFR 172 Subpart H Training must be complete within 90 days after assignment to hazmat duties Subject Areas General awareness and familiarization Function specific Safety training Security Awareness Training In-Depth Security Training

DOT Hazmat Training Information http://www.phmsa.dot.gov/hazmat/training/publications Hazmat General Awareness Familiarization Training CD FREE Hazmat Digipack 7.1 Security Awareness FREE Hazmat Transportation Training Modules 5.1 - $25 Check catalog for other publications

Hazmat Training In-Depth Security Training Effective October 1, 2010 Old: Yellow III Highway Route Control Quantity New: IAEA Category II per package

Hazmat Training In-Depth Security Training Written Security Plan Personnel Security Unauthorized Access En-route Security New Site Specific New Annual Site Specific Assessment

Hazmat Training Record Keeping Record keeping is the key Maintain during employment and 90 days thereafter Hazmat employees name Most recent Hazmat training completion date

Hazmat Training Record Keeping Description, copy or location of hazmat training materials Name and address of person providing training Certification hazmat employee has been trained and tested

Don’t

Safety Emergency Response Information Available away from package Not required to attached emergency instructions MSDS sheet not applicable to radioactive materials Emergency Response Guidebook (2012)

Safety Emergency Response Guidebook Available for download at hazmat.dot.gov Facility Operators: Must be immediately available where hazardous material is received, stored or handled during transportation. Carrier: Maintain on board with shipping paper information, notice to pilot in command, or dangerous goods manifest

Twenty-Four Hour Telephone Emergency Number Monitored at all times hazardous material is in transportation, including storage incidental to transportation Pagers may not be used Answering services may be used if forwarded immediately (risky) Answering services may be given appropriate information (risky)

Twenty-Four Hour Telephone Emergency Number Telephone number of person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material or who has immediate access to a person who posses such knowledge and information

Twenty-Four Hour Telephone Emergency Number Shipper’s name and Emergency Telephone Number of Shipper or Emergency Response Information (ERI) provider contracted by shipper. If shipper does not contract with ERI provider then name or contract number of third party who authorizes shipper to use the ERI provider under their contract.

Type A Package To my current best knowledge No Type A packages are available for purchase off the shelf that fully meet the Type A package documentation requirements Except the Biodex packaging system for F-18 Except the Croft Type A Packages No package testing company can fully provide complete Type A package documentation.

Type A Package Many shippers think that only the tests are required for Type A package documentation. Criteria no loss or dispersal of radioactive contents no loss of shielding integrity which would result in more than a 20% increase in the radiation level at any external surface of the package.

Type A Package Type A package documentation must address all the points in 173.410 General Design Requirements 173.412 Additional Design Requirements for Type A Packages 173.465 Type A Packaging Tests 173.466 Additional Tests for Type A Packages Designed for Liquids and Gases.

Thank You Roy A. Parker, Ph.D. Radiation Physicist 5061 Abelia Drive Baton Rouge, Louisiana 70808 Tel: 225-924-1473 Fax: 225-924-4269 Email: roy@royparker.org

Roy A. Parker, Ph.D.