When radioactive materials are transported via public routes (i.e. highways, airways, waterways, etc.), rules and regulations promulgated by the Department of Transportation (DOT) apply to protect members of the general public who are not radiation workers from radiation exposure which could result from an accident.

DOT requires any worker who is involved in hazardous materials packaging and transportation to receive initial training, as well as biennial refresher training. At UWM this applies to persons who are involved in the transport of radioactive material:

• to and from UWM facilities by motor vehicle (i.e., CGLS, Field Station)
• to and from remote research facilities
• prepare packages of radioactive material for shipment off-campus

Each authorized user is responsible for insuring that their staff members meet the training requirements if their program involves packaging and/or transporting radioactive materials. To comply with the Hazardous Materials Transportation Act (HMTA), the DOT promulgated Hazardous Material Regulations codified in Title 49 Code of Federal Regulations (49 CFR), Parts 171 to 177 and Parts 178 to 180. The NRC requires (10 CFR 71.5) each radioactive materials licensee who transports licensed materials to comply with the regulations appropriate to the mode of transport used as written in 49 CFR Parts 170 through 189. While each of the subparts of 49 CFR 173 also apply to transportation of radioactive materials, 49 CFR 173 subpart I is devoted exclusively to radioactive materials.

The information presented here is intended to be a comprehensive guide to the more prominent and basic regulatory requirements for the safe transportation and handling of radioactive materials. Information is included on the shippers' requirements for limitation of activity content of packages, packaging, labeling, shipping documentation and control of radiation and contamination. Basic guidance is also included on the handling of transport incidents and emergencies during the transport of radioactive materials.

This information is a summary of the present regulations therefore, 10 CFR 49 and/or IAEA guidelines should be consulted for further information.

The Department of Transportation defines radioactive materials as materials with a specific activity greater than 0.002 µCi/g (74 Bq/g) as radioactive, hazardous material. For purposes of transportation radioactive materials having a specific activity not exceeding 0.002 µCi/g (74 Bq/g) are not subject to regulations in transportation. This is, however, a "de minimis" level which applies only to transportation. For purposes of licensing during use and possession, such materials may still be subject to regulation by the NRC.

The Hazardous Materials Regulations apply to substances listed in the Hazardous Materials Table, 49 CFR 172, Subpart B. This table lists almost 3000 hazardous materials descriptions with their proper shipping names. The shipper is responsible for determining whether a material is a hazardous material, either by identifying it with a proper shipping name listed in the Hazardous Materials Table, or by determining if it fits in one of the hazard classes listed in 49 CFR 173.2 in accordance with the reference for definitions in 49 CFR 173. The transporter of the material must be familiar with these regulations and is expected to verify the proper packaging of materials they transport.

As stated above, any radioactive material with a specific activity greater than 0.002 µCi/g (74 Bq/g) is considered a hazardous material and is subject to DOT rules. Once identified as radioactive, its description and shipping name need to be identified to properly label the package for shipping. With the possible exception of multiple or mixed hazards (e.g., a poison flammable radioactive material), most of the radioactive material shipped from UWM will have a proper shipping name listed in the Hazardous Materials Table. Any material meeting the definition of more than one hazard class must be classed according to the list in 49 CFR 173.2(a). If you suspect you may be shipping a material of mixed hazards and you don't know how to classify it, call University Safety and Assurances. Table 1 extracts a portion of this table and explanations of the information in the various columns is outlined below.

• Column 1 - Symbols - Special "notes" which apply only to certain materials, e.g., a "D" in Column 1 means that the shipping name that follows is only applicable to domestic shipments. A key to the symbols in Column 1 is found in 49 CFR 172.101 (b)
• Column 2 - Hazardous Material Description and Proper Shipping Name - The name by which the hazardous material is defined. There is a hierarchy in selecting the proper shipping name. Names should be selected by the first thing that accurately describes them among
  • chemical technical name (e.g., thorium nitrate, solid)
  • chemical family name (e.g., alcohols, n.o.s.) n.o.s. means not otherwise specified
  • end use description (e.g., compound, cleaning liquid)
  • end use description n.o.s. (e.g., refrigerant gases, n.o.s.)
  • hazard class description (e.g., radioactive material, n.o.s.)

See Table I: 172.101 Hazardous Materials Table (extracted1)

• Column 3 - Hazard Class or Division - A numerical designation indicating the hazard corresponding to the proper shipping name in Column 2 or the word forbidden. If a material is designated as forbidden, it must not be transported.
• Column 4 - Identification Number - An ID number assigned to each proper shipping name. Numbers preceded by a UN are associated with proper shipping names appropriate for international as well as domestic transport. Those numbers preceded by a NA are for proper shipping names not covered by international dangerous goods transportation standards or not addressed by international standards for emergency response, except for transportation between the U.S. and Canada.
• Column 5 - Packing Group - One or more of the numbers I, II, or III assigned to each proper shipping name which designates the degree of hazard associated with each material. Packing Group I materials present the greatest hazard, Packing Group III materials present the least. This is not to be confused with the radioactive label category that is described later in this document.
• Column 6 - Label(s) Required - The warning label required for package containing material in this hazard class and proper shipping name category, unless the package is otherwise excepted.
• Column 7 - Special Provisions - Codes corresponding to special packaging and handling requirements as described in 49 CFR 172.102.
• Column 8 A, B, C - Exceptions - Numbers in these columns refer to the section of 49 CFR 173 that describes packaging for the material in this hazard class and shipping name. Exceptions for packaging requirements for radioactive materials will be specified later.
• Column 9 A, B - Quantity Limitations - These columns describe quantity limitations and/or when the material is forbidden to be transported by a specific mode of transportation (e.g., passenger aircraft). These apply to radioactive materials mostly that contain another hazard (e.g., uranyl and thorium nitrate are oxidizers as well as being radioactive).
• Column 10 A, B - Vessel Stowage Requirements - These columns describe where and how hazardous material must be stored on commercial cargo and passenger vessels (this does not apply to materials taken aboard the Neeskay). 10A refers to "on deck", "below deck", or "forbidden." 10B has special stowage requirements for specific materials described in 49 CFR 176.84.

As mentioned above, the Hazardous Materials Regulations are formulated to insure that members of the general public are not put at risk from hazardous cargoes being transported on our public transportation network. Safety in the transport of radioactive materials is accomplished mainly by the use of proper packaging; considering the type, quantity and form of the material; and by limitization of the level of radiation from the material.

The basic concepts of material packaging requirements are that (1) hazardous materials packaging must be of sufficient strength and quality to withstand normal transportation conditions and high-probability accidents, and (2) the package selected by the shipper must be compatible with the material to be shipped and must be suitable to the level of the risk presented by the material.

The type of package which will generally be required for transporting radioactive material at or from UWM should usually be one of two types: (1) Strong, tight packages for transporting limited quantities of radioactive materials or (2) Type A packages for transporting materials in amounts exceeding limited quantities.

As previously discussed, the Department of Transportation defines radioactive material as material having a specific activity greater than 0.002 µCi/g (74 Bq/g). Transportation of radioactive materials is regulated jointly on a federal level by the Nuclear Regulatory Commission and the Department of Transportation. Hazardous Materials Regulations as they apply to radioactive materials are described in 49 CFR 173 Subpart I.

The following are some commonly encountered terms and definitions.

A₁

Based on external radiation hazards, the maximum activity of special form material permitted in a Type A package, such that its escape from the packaging would cause only a direct radiation hazard.

A₂

Based on radiotoxicity, the maximum activity of normal form radioactive material (other than special form or low specific activity radioactive material) permitted in a Type A package, such that its escape from the packaging would present both a radiation and a contamination hazard.

A list of A₁ and A₂ quantities is found on page 16 in Table 7.

Limited Quantity of Radioactive Material

A quantity of radioactive material not exceeding the limits in Table 2. Much of the radioactive material shipped from UWM will fall into this category. Additional information on the restrictions and packaging requirements for limited quantities are provided on page 11.

Low Specific Activity

Radioactive material with limited specific activities which satisfies the descriptions and limits set below. Although there are three LSA classes, (LSA-I, LSA-II, and LSA-III) at UWM, only LSA-II and LSA-III are applicable (LSA-I pertains to ores only) and pertain to material in which the radioactivity is essentially uniformly distributed and in which the estimated average concentration of the contents does not exceed those specified.

LSA-II -

Water with tritium concentration up to 20.0 Ci/liters.

• - Materials in which the radioactive material is distributed throughout and the estimated average specific activity does not exceed 10-4 A2 per gram for solids and 10-5 A2 per gram for liquids.

LSA-III Solids (e.g., consolidated wastes and gases, activated materials) in which:

• The radioactive material is distributed throughout a solid or a collection of solid objects, or is essentially uniformly distributed in a solid compact binding agent (e.g., concrete, bitumen, ceramic, etc.), and
• The radioactive material is relatively insoluble, or is intrinsically contained in a relatively insoluble material, so that, even under loss of packaging, the loss of radioactive material per package by leaching (when placed in water for seven days would not exceed 0.l A2, and
• The estimated average specific activity of the solid does not exceed 2 x 10-3 A2 per gram.

Transport requirements for LSA radioactive materials are found in 49 CFR 173.427.

Normal Form Radioactive Material

Radioactive material which has not been demonstrated to qualify as Special Form Radioactive Material

Package

The packaging together with its radioactive contents as presented for transport.

Packaging

The assembly of components necessary to ensure compliance with packaging requirements. As described, it may consist of absorbent materials, spacing structures, radiation shielding, etc.

Radioactive Article

Any manufactured instrument and article such as a clock, electronic tube, apparatus, or similar instruments and articles having radioactive material as a component part.

Radioactive Material

Any material having a specific activity greater than 0.002 µCi/g (74 Bq/g). Activities listed in 49 CFR 172.101, Appendix A, Table 2 (List of Hazardous Substances and Reportable Quantities) which designate a Hazardous Substance as a Hazardous Material.

• - Hazardous material is a substance which as been determined by the DOT to be capable of posing an unreasonable risk to health, safety and property when transported in commerce and which as been so designated.
• - Hazardous substance is a quantity of a hazardous material exceeding the reportable quantity.

Special Form Radioactive Material

Radioactive material which satisfies the following conditions:

• It is either a solid piece or is contained in a sealed capsule that can be opened only by destroying the capsule
• The piece or capsule has at least one dimension not less than 5 millimeters
• Satisfies test requirements of 49 CFR 173.469

At UWM, special form material would only be those sealed sources that are accompanied by special form certification. The large majority of material offered for transport by UWM is Normal Form Radioactive Material

Specific Activity

The radioactivity of the radionuclide per unit mass of that nuclide. The specific activity of a material in which the radionuclide is essentially uniformly distributed is the radioactivity per unit mass of the material.

Surface Contaminated Object (SCO)

Any non-radioactive and non-activated solid materials which is not itself radioactive but which as radioactive contamination not exceeding the fixed, and total contamination limits in Table 4 distributed on its surfaces. SCO is not intended to include contaminated paper, plastic, booties, gloves and other similar lab trash. If the material is activated, or activated and contaminated, it cannot be classified as SCO. When SCO-II limits are exceeded, and depending on the fraction of the aggregate A2 values, the shipment must be made in Type A or Type B package, as a Type A or Type B quantity.

Transport Index (TI)

The dimensionless number rounded up to the first decimal place, placed on the label of the package to designate the degree of control to be exercised by the carrier during transportation. For nonfissile material, the transport index is determined as the maximum radiation level in millirem per hour at 1 meter (3.3 feet) from the external surface of the package. Table 5 provides transport index information at various dose rates.

Type A Package

Packaging designed to retain the integrity of containment and shielding required under normal conditions as demonstrated by specific performance-based tests.

Type A Quantity

A quantity of radioactive material, the aggregate radioactivity of which does not exceed A1 for special form or A2 for normal form radioactive materials.

Most operational rules apply to those who manufacture, test and repair certain containers like tank cars, cargo tanks and Type B containers. There are also operational requirements for all shippers and carriers, as well as special requirements for each mode of transportation: rail, air, water and highway. Operational requirements are defined in 49 CFR 171 through 180 and 49 CFR 390 through 397.

Two of the primary operational rules that will affect personnel shipping material at UWM are:

• packages of hazardous materials must be blocked or braced during shipment
• persons operating a vehicle placarded for hazardous materials must have a Commercial Driver's License (CDL) with a hazardous materials endorsement

The goal of hazard communication (e.g., shipping papers, labeling, placarding, etc.) is to help prevent problems at the scene when responding to a transportation accident by providing hazard identification information to offerers/shippers, carriers and emergency responders. Hazard communication has five components:

1. Shipping Papers - With few exceptions, (e.g., limited quantities of radioactive materials, previously discussed), any hazardous material offered for shipment via a commercial courier must be declared as dangerous goods/restricted articles as described in the shipping paper per 49 CFR 172.201 - 172.205. All shipping papers must include contents, name of shipper if shipment is to be by water, continuation page if necessary, and emergency response telephone number as described in 49 CFR 172.604. The emergency response telephone number must be the number of a person who is knowledgeable about hazardous materials and emergency response and who will be available 24 hours per day. At UWM we use the Radiation Safety Program office number of (414) 229-4275 as the 24 hour emergency number.

   In addition to proper shipping name, hazard class, and UN #, shipping papers for radioactive materials must contain the following:

   • the words Radioactive Material unless these words are part of the proper shipping name
   • the name or abbreviation of each radionuclide (e.g., I-125 or Iodine-125)
   • a description of the physical and chemical form of the material
   • the activity in bequerel (Bq) and, optionally, in curies, millicuries, microcuries, etc
   • the label category applied to the shipment (i.e., Radioactive White I, Yellow II, Yellow III). Proper labelling will be discussed later.
   • the transport index applied to each package of a shipment bearing Radioactive Yellow II or Radioactive Yellow III label

   To assist emergency responders, these shipping papers must be both readily available and visible. When the driver is at the wheel, the shipping papers must be within his or her immediate reach and readily visible to a person entering the driver's compartment or in a holder which is mounted to the inside of the door on the driver's side of the vehicle. When the driver is not at the wheel, the shipping paper shall be in a holder mounted to the inside of the driver's side door or on the driver's seat.

2. Marking - Required marking for hazardous materials packages are described in 49 CFR 172 Subpart D. Required marking for nonbulk packages are:
   • proper shipping name and identification number
   • technical name
   • consignee's or consignor's name and address

   There are additional requirements for marking packages containing radioactive materials as described in 49 CFR 172.310. Some of these include:

   • packages which conform to the requirements for TYPE A packages must have TYPE A clearly marked on them
   • packages offered for export must have USA clearly marked on them
   • packages containing liquid hazardous materials must have orientation markings on two opposite vertical sides of the package
3. Labeling - In addition to marking, the shipper must also apply a label to each package of hazardous material. A label is required for each hazard if the material has multiple hazards. Label requirements for radioactive materials are described later within this document.
4. Placarding - Hazardous materials transported by highway and rail must be placarded on each side and each end of the vehicle to display the hazard class of the material. For radioactive materials, only shipments bearing the Yellow III label or material shipped as LSA-Exclusive Use need be placarded.
5. Emergency Response Information - Each shipment of hazardous materials must be accompanied by information that can be used in the mitigation of an incident involving the material, including:
   • immediate hazards to health
   • risks of fire or explosion
   • immediate precautions to be taken
   • handling methods in case of leaks or fires
   • the 24 hour emergency response telephone number

Limited quantities of radioactive materials are excepted from specification packaging, shipping paper certification, marking and most labeling requirements. They are not, however, without restrictions. In addition to being below the limits in Table 3, radioactive materials that are to be shipped as limited quantity must meet the following requirements:

1. The material must be packaged in a strong, tight, vibration tested (i.e., UN-designated) package that will not leak any of the radioactive materials under conditions incidental to normal transport.
2. The radiation level at any point on the external surface of the package must not exceed 0.5 millirem per hour.
3. Regulations require that removable contamination on the external surface of the package must not exceed 2200 dpm/100 cm2(3.7 Bq/100 cm2) for ß/? emitting radionuclides and nuclides with half lives of less than 10 days OR 220 dpm/100 cm2 (3.7 Bq/100 cm2) for a emitting radionuclides. In practice, if the contamination level exceeds 2 times background, determine the source of the contamination, take corrective actions, repackage the material and rewipe.
4. The outside of the inner packaging, or if there is no inner packaging, the outside of the package itself must bear the marking Radioactive.
5. The package must be certified as being acceptable for transportation by having a notice enclosed in or on the package, included with the packing list, or otherwise forwarded with the package. The notice must include the name and address of the consignor or consignee and include the following statement:

   This package conforms to the conditions and limitations specified in 49 CFR 173.421 for radioactive material, excepted package-limited quantity of material, UN 2910

   An example of this notice is shown in Appendix A.

6. Emergency response information must be included with each shipment of radioactive material --- limited quantities are not excepted from this requirement. In the event of an emergency during shipment of the package we, as the "originator" of the package, must be available to convey information about the contents of the package and appropriate emergency actions to take. Use the Radiation Safety Program phone number (414) 229-4275 as the emergency contact number.

If the quantity of radioactive materials shipped is greater than the "limited quantity", it can not be excepted from specification packaging, shipping papers, marking and labelling requirements. For greater than limited quantity shipments these additional restrictions apply:

1. Packaging Specifications - Materials must be shipped in a Department of Transportation, Specification 7A Type A container or other container authorized as Type A in 49 CFR 173.415. Each shipper of a Specification 7A Type A package must maintain on file for at least one year after the latest shipment, and will provide to the DOT on request, complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods, packaging designs and materials of construction comply to that specification. This certificate should be available from the manufacturer and/or vendor of the container.
2. External Radiation Levels - Each package of radioactive materials offered for transportation must be designed and prepared for shipment so that under conditions normally incident to transportation the radiation level does not exceed 200 millirem per hour at any point on the external surface of the package, and the transport index does not exceed 10.
3. Marking - All required marks must be durable, in English and printed on the package surface (or on a label), displayed on a background of sharply contrasting color, unobscured by labels or other markings. Be sure that each package containing Type A materials is marked as follows:
   • Proper shipping name - The proper shipping name and corresponding identification number must be marked on the outside of the package. Most Type A packages shipped from UWM should be labeled:

     Radioactive Material, n.o.s., UN2982

     • Package Specification Identification - Each Type A package must be marked as "USA DOT 7A, Type A". The letters and numbers must be at least 1/2 inch high.
     • Name and Address of Consignor - If the material is being shipped from UWM, our name and address must appear on the package.
     • Radioactive Liquids - The package must be marked "This Side Up" or "This End Up". Make sure the container has an upright orientation.
4. Labeling - This refers to the 4" x 4" RADIOACTIVE MATERIAL - WHITE I, YELLOW II, OR YELLOW III label (also to Explosive, Oxidizer, Poison, Corrosive, etc. labels). The proper label to be affixed to a package of radioactive material is based on the radiation level at the surface of the package (RL) and the transport index (TI), a dimensionless number, based on the maximum radiation level (millirem per hour) at 1 meter or 3.3 feet from the surface of the package. Any package required to have a Radioactive label must have two of these labels affixed to opposite sides of the package. Examples of labels can be found in Appendix B.

   TABLE 6. Radioactive Label Category

   Transport Index (TI)	Package Surface Radiation Level (RL)	Label Category
   TI = 0	RL < 0.5 mrem/hr	White-I
   TI = 1.0	0.5 mrem/hr < RL < 50 mrem/hr	Yellow-II
   1.0 < TI < 10	50 mrem/hr RL < 200 mrem/hr	Yellow-III

5. Shipping Papers - Shipping papers and emergency response information must accompany the shipment.
6. Placarding - If a vehicle contains a package labeled with a Radioactive Yellow III label, placarding is required and the driver must have a Commercial Drivers License (CDL). If the radiation level at the surface of your package and/or the transport index is high enough to require a Yellow III sticker (i.e., TI > 1.0 or RL > 50 mrem/hr), call the Radiation Safety Program at 229-4275. With proper packaging and shielding, it may be possible to reconfigure the package so it will be a Radioactive Yellow II.

If a package contains "multiple hazards", additional requirements need to be considered. For transportation purposes, dry ice is considered a hazard so special procedures need to be followed. Following the restrictions in 49 CFR 173.421-2, the procedures for shipping radioactive material on dry ice via air include:

1. Dry ice packaging (e.g., styrofoam liner and outer box) must be used.
2. The package must be marked (on one side) with the warning diamond which has vertical black bars on the top half and a 9 on the bottom half.
3. Additionally, on the same side as the diamond must appear the words: ________ Kg ( lbs) DRY ICE
   UN 1845
4. The dry ice and number of pounds must be identified on the shipping papers. Most carrier bills of lading have a space for dry ice identification and often require the number of pounds be listed under the UN1845.

As previously discussed, in the event of an emergency during the shipment of a package of radioactive material, the originator of the package must provide a phone number and contact person that emergency personnel could contact for further information of the shipment. At UWM we use the Radiation Safety Program number (414) 229-4275 and Sharron Daly, RSO, as the emergency contact person. If a call were to come in after hours it would be transferred to UWM Police who have the home phone number of additional persons to contact.

The transporter of the material must also accept some of the responsibility for emergency response. A packet of emergency information must be in the transporter's possession during the entire time they are traveling. The packet must be clearly visible in the front seat of the vehicle and the driver must have immediate access to the information at all times --- it can't be in the trunk, packed in a box, or in someone's brief case.

In most accidents, the requirements for shipping containers of radioactive materials should be adequate to assure that in the event of an accident an undamaged packaged will be safe. However, damaged packages may or may not pose an external hazard. In an emergency, priority response actions (e.g., lifesaving, fire control, rendering first aid, etc.) may be performed before taking radiation measurements. In any emergency situation:

• Isolate the hazard area and deny entry. Call the emergency response number on the shipping paper first. Call the number(s) listed on the Emergency Phone List next.
• Life threatening injuries must be attended to by a qualified health care specialist. Uninjured persons or equipment with suspected contamination should be detained or isolated and remain accessible to Radiation Safety personnel. Delay cleanup until instructions are received from the Radiation Safety Program.
• Unless absolutely necessary, (e.g., removal from fire), do not touch damaged/spilled containers or materials.
• Remain in the area and keep the area secure until emergency response personnel arrive.