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Transportation of Radioactive Material by Air

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

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Transportation of Radioactive Material by Air

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

  2. 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

  3. 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

  4. 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.

  5. 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

  6. 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

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

  8. 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

  9. 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

  10. 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

  11. M Y T H

  12. 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)

  13. 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

  14. Don’t

  15. Do RQ Sequence

  16. Radioactive Materialsand 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)

  17. 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

  18. 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 Table49 CFR 172.101 • Affects package checklist and training

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

  20. Radioactive Material with Subrisk – Cargo Aircraft Only

  21. Radioactive Material with Subrisk – Passenger Aircraft

  22. FedEx ExpressIDG Label

  23. FedEx ExpressIDG 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.

  24. Overpack Shipping Paper Format Issue

  25. Overpack Shipping Paper Format Issue

  26. Overpack Shipping PaperFormat 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.

  27. Approved SoftwareFX-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]

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

  29. 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

  30. 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 sourceIATA 10.8.3.9.2 Step 7 • Activity on label must correspond to declaration

  31. RQ Radioactive Material Excepted Package • Modified Shippers Declaration

  32. 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.

  33. Passenger and Cargo AircraftCargo Only Aircraft • Not type of aircraft but package classification

  34. Security Category 1

  35. 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.

  36. Security Category 2

  37. 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.

  38. Security Category 3

  39. 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.

  40. 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.

  41. 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.

  42. Hazmat Training49 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

  43. 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

  44. 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

  45. Hazmat Training49 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

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

  47. Hazmat TrainingIn-Depth Security Training • Written Security Plan • Personnel Security • Unauthorized Access • En-route Security • New Site Specific • New Annual Site Specific Assessment

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

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