{"operation":"document","citation":"04-0085","title":"Hbar Technologies, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-10-19","effective_on":null,"summary":"04-0085 response to Hbar Technologies, LLC concerning 171.8.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0085.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0085.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0085","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040085.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nspecial Programs\nOCT 19 2004\nAdministration\nDr. Gerald P. Jackson\nRef. No. 04-0085\nPresident\nHbar Technologies, LLC\n1275 Roosevelt Road, Suite 103\nWest Chicago, IL 60185\nDear Dr. Jackson:\nThank you for your March 24, 2004 letter regarding the classification of antiprotons under the\nHazardous Material Regulations (HMR; 49 CFR parts 171-180). Specifically, you ask whether\nantiprotons, transported in quantities capable of producing a worst case acute exposure to the\npublic of no more than 2 mrem or 1,000 rem from prompt ionizing radiation, are considered a\nhazardous material, and if so, which category (hazard class and division) applies. You state that\nthe antiprotons are intrinsically stable and would only emit radiation upon contact with residual\ngas within the bottle or the walls of the bottle.\nYour letter does not provide sufficient information on the hazardous properties of your particular\nmaterial, the amount of material to be transported, or the manner in which the material is\npackaged to provide you with specific guidance. Nevertheless, based upon the information you\nprovided, we believe that sufficient quantities of antimatter offered for transportation would meet\nthe defining criteria of a Class 1 (explosive), a Class 7 (radioactive), and perhaps other Class\nmaterial. For example, a dose of 1,000 rem of prompt ionizing radiation to the public is\nsignificantly greater than the defining annual dose criteria for Class 7 (radioactive) material. As\nwith other hazardous materials, we also believe a graded approach based on the quantities of\nantiprotons and their related possible effects would be appropriate.\nWe recognize that antimatter is not specifically listed in the HMR and the need for possible\nfuture rulemaking on this emerging technology. In order to complete our review of your\nproposed single transport of antiprotons later this year from the Fermi National Accelerator\nLaboratory in Batavia, IL to the NASA Marshall Space Flight Center in Huntsville, AL, we have\nidentified the following issues pertaining to your request.\nMaterial\n1) Provide information on the material purity as well as the method and accuracy of measuring\nthe quantities of antiprotons proposed to be transported.\n2) Provide the quantities of antiprotons that you may desire to transport, based on your\nevaluation of the information requested in this letter.\n040085\n171.8\n\n<<<PAGE 2>>>\n\nContainment System\n3) Describe the antimatter transport bottle, including design features such as materials of\nconstruction, barriers, shielding, vacuum system, cryogenics, superconducting magnets,\ndetection systems for loss of design feature functions or annihilation of the antiprotons, and\ncontingency backup systems.\n4) Provide information on magnetic fields produced by the bottle system.\n5) Describe any other hazardous materials present other than antiprotons, such as helium or\nother compressed or liquefied gas, batteries, or fuels.\nFailure Modes\n6) Detail the processes, such as prolonged or rapid loss of vacuum, cryogenics, or\nelectromagnetic containment in the transport bottle, that could cause annihilation of the\nantiprotons with matter, as well as information on any steady state annihilation.\n7) Provide information on any past experience with planned or unplanned stored antiproton\nannihilation.\nTransport\n8) Provide details on the truck and any design features, such as shielding or barriers, to be used\nfor the transport.\n9) Provide details on any operational controls or contingency planning to be used during\ntransport.\n10) Provide details on any personnel or environmental monitoring for hazardous materials to be\ninstituted during transport, such as dosimetry selection for prompt or delayed radiation\nhazards, including radiation type and energy coverage as well as any applicable accreditation.\nConsequences\n11) Provide the supporting information for the ionizing radiation exposure determination you\nand processes, including energies and decay times. Provide information on the total effective\nprovided from antiproton annihilation with matter, specifying contributions from all products\ndose equivalent, deep dose equivalent, committed effective dose equivalent if any, committed\ndose equivalent if any, shallow dose equivalent, and lens dose equivalent; and quality factors\nused. Include contribution from decay chain daughter products. Provide spatial and time\ndata.\n12) Provide an analysis of the level of safety of the bottle under normal and accident conditions\nduring transport that could lead to annihilation of the antiprotons with matter.\n\n<<<PAGE 3>>>\n\n13) Provide information on possible fission effects caused by antiproton annihilation with matter,\nsuch as caused by pions or high-energy gamma rays, on any transuranic and fissile material\nthat may be impacted.\n14) Provide information on airborne radioactivity, radioactive material contamination, and\ninduced activation caused by the antiproton annihilation.\n15) Your memo provides data for a single prompt dose to the public. Provide the quantity of\nantiprotons that would cause this dose and the assumptions used. Provide the total, and not\njust prompt dose, if the total dose is different. Provide estimated total doses to any transport\ntotal doses estimated\nworkers and the assumptions, such as distance, utilized. Provide a time and spatial plot of\n16) Provide data on heat generated and the explosive potential of the antiprotons annihilating\nwith matter.\n17) Explain the correlation of effects based on the quantity of antiprotons, e.g., linearity, or any\nphenomena that would cause non-linear or threshold effects based on the quantity of\nantiprotons.\nGeneral\n18) Estimate the margin of error in any calculations or experimental data you provide.\n19) Provide references used and details on any computer codes used to provide information\nrelevant to these issues, and any verification and validation performed.\n20) Provide details on the credentials and backgrounds of personnel involved in providing\ninformation relevant to the issues, including peer reviewers.\n21) Provide any test data that substantiates calculated data, or of any physical testing that is\nplanned to be conducted to corroborate any calculated data.\nHazardous Materials Technology, (202) 366-4545.\nShould you have further questions on this matter, please contact Mr. Jim Williams, Office of\nSincerely,\nRobert A. McGuire\nAssociate Administrator for\nHazardous Material Safety\n\n<<<PAGE 4>>>\n\nIn my opinion, this is a good start at a letter. I have annotated this using the Microsoft Word\nindly regard all of my suggestions in the context of USDOT practices and existing Regulation:\nrack Changes features for my own convenience. Don Cossairt, October 12, 2004. Pleas\nBetts\nhere at Fermilab who take care of that topic for me!\nAs I explained over the telephone, 1 am not an expert per se on DOT procedures. We have others\n$111.8\nDefinitions\n04-0085\nPresident\nDr. Gerald P. Jackson\nRef. No. 04-0085\n1275 Roosevelt Road, Suite 103\nHbar Technologies, LLC\nWest Chicago, IL 60185\nDear Dr. Jackson:\nHazardous Material Regulations (HMR; 49 CFR parts 171-180). Specifically, you ask whether\nThank you for your March 24, 2004 letter regarding the classification of antiprotons under the\nantiprotons, transported in quantities capable of producing a worst case acute exposure to the\nhazardous material, and if so, which category (hazard class and division) applies. You state that\npublic of no more than 2 mrem or 1,000 rem from prompt ionizing radiation, are considered a\ngas within the bottle or the walls of the bottle. In my judgment it seems to me Hbar has asked\nthe antiprotons are intrinsically stable and would only emit radiation upon contact with residual\nintroduce early in this letter the possibility that several levels of stringency will be required at\nfor advice over a rather wide range of worst case doses. I suggest that DOT point that out and\ndifferent points just like what is done for other ionizing radiation hazards.\nmaterial, the amount of material to be transported, or the manner in which the material is\nYour letter does not provide sufficient information on the hazardous properties of your particular\nprovided, we believe that sufficient quantities of antimatter offered for transportation would meet\npackaged to provide you with specific guidance. Nevertheless, based upon the information you\nthe defining criteria of a Class 1 (explosive), a Class 7 (radioactive), and perhaps other Class\nyou should still list explosive hazard. I believe the latter hazard is more likely to present itself\nmaterial. In my view, I would point out Class 7 first, as I think this the \"exotic\" issue. However\nannihilations themselves for the quantities of antiprotons they are talking about transporting. See\ndue to the nature of the technology used to create the bottle than from the antiproton\nomments below concerning other hazards. For example, a dose of 1,000 rem of prompt ionizin\nadiation to the public is significantly greater than the defining annual dose criteria for Class\nDeleted:\n(radioactive) material. Again, the worst case dose is crucial to determining what DOT might\nrequire, I suggest.\nWe recognize that antimatter is not specifically listed in the HMR and the need for possible\nfuture rulemaking on this emerging technology. In order to complete our review of your\nproposed single transport of antiprotons later this year from the Fermi National Accelerator\n\n<<<PAGE 5>>>\n\nidentified the following issues pertaining to your request to determine if the proposed quantity\nLaboratory in Batavia, IL to the NASA Marshall Space Flight Center in Huntsville, AL, we have\nmeets the defining criteria for hazard classes and divisions in the HMR.\nMaterial\n1)\n•Provide information on the material purity as well as the method and accuracy of measuring\nthe quantities of antiprotons proposed to be transported. This is a good issue. They should be\nimagine it will make a difference in what requirements will be prescribed.\nable to describe to you how they will know how many antiprotons they have in the bottle as I\n2)\nProvide the quantities of antiprotons that you may desire to transport, based on your\nevaluation of the information requested in this letter. They did. indeed, as for a big range!\nContainment System\n3) Describe the antimatter transport bottle, including design features such as materials of\nconstruction, barriers, shielding, vacuum system, cryogenics, superconducting magnets, and\ndetection systems for loss of design feature functions or annihilation of the antiprotons.\n4) Provide information on magnetic fields produced by the bottle system. Yes, there will be\nstray magnetic fields. In my limited expertise with DOT, I cannot recall any requirements\npertaining to magnetic fields.\n5)\nDescribe any other hazardous materials present, such as helium. Is helium really a hazardous\nmaterial per DOT (pardon my ignorance!). Under some situations it can be an asphysixiant.\nFailure Modes\n6) Detail the processes, such as shock, prolonged or rapid loss of vacuum, cryogenics, or\nantiprotons with matter, as well as information on any steady state annihilation. Good issue\nelectromagnetic containment in the transport bottle that could cause annihilation of the\nand loss of electromagnetic containment. You might want to ask about backup systems, if\nto raise, you have brought up the 2 key problems that can cause annihilations; loss of vacuum\nis a problem but they should address this.\nany, that might be present to assure this does not happen. I doubt if steady-state annihilation\n7) Provide information on any past experience with planned or unplanned stored antiproton\nannihilation.\nTransport\n8) Provide details on the truck and any design features, such as shielding or barriers, to be used\nfor the transport. Good.\n\n<<<PAGE 6>>>\n\n9) Provide details on any operational controls or contingency planning to be used during\ntransport._Good.\n10) Provide details on any personnel or environmental monitoring for any hazardous materials\nmonitoring for possible prompt radiation hazards. I don't believe other hazardous materials\nduring transport. I suggest restating this point to cover personnel or environmental\nchoice of dosimetry badge is crucial. Due to the nature of the radiation fields, they would\nare a significant issue. However, if it is decided to require personnel monitoring badges, the\nhave to select dosimeter that is capable of seeing fast neutrons as well as gamma-rays. I\nwould insist on a NVLAP-accreditated badge inclusive of fast-neutron capability.\nConsequences\n11) Provide the supporting information for the ionizing radiation exposure determination you\nprovided from antiproton annihilation with matter, specifying contributions from all products\ndose equivalent, deep dose equivalent, committed effective dose equivalent if any, committed\nand processes, including energies and decay times. Provide information on the total effective\nused. Include contribution from decay chain daughter products. Provide spatial and time\ndose equivalent if any, shallow dose equivalent, and lens dose equivalent; and quality factors\nthem tell you that. From my own work, it will all be deep dose equivalent as all of the major\ndata. I think this is nearly all a \"prompt\" situation with insignificant decay products, but let\ncomponents of the radiation field have sizeable mean-free paths in tissue. At one point a\neffects that my paper didn't and generally underestimated the doses. We'll see what they\ncrude calculation had been done by one of G. Jackson's partners. However, it left out some\nsubmit here.\n12) Provide an analysis of the level of safety of the bottle under normal and accident conditions\ncomment about failures above.\nduring transport that could lead to annihilation of the antiprotons with matter. See my\n13) Provide information on possible fission caused by antiproton annihilation with matter, such\nbe impacted. Fission won't be a problem unless they shield the bottle with uranium!\nas caused by pions or high-energy gamma rays, on transuranic and fissile material that may\nHowever, should they, for some reason not obvious to me, choose depleted uranium as a\n14) Provide information on airborne radioactivity, radioactive material contamination, and\nshield to make the thing compact, fission would have to be considered.\ninduced activation caused by the antiproton annihilation. These should be non-issues for the\nguantities envisioned here. However, they should state their conclusions on this.\n15) Your memo provides data for a single prompt dose to the public. Provide the quantity of\njust prompt dose, if the total dose is different. Provide estimated total doses to any transport\nantiprotons that would cause this dose and the assumptions used. Provide the total, and not\ntotal doses estimated._See comment above concerning calculations that might be outdated.\nworkers and the assumptions, such as distance, utilized. Provide a time and spatial plot of\n\n<<<PAGE 7>>>\n\n16) Provide data on heat generated and the explosive potential of the antiprotons annihilating\nwith matter.\n17) Explain the correlation of effects based on the quantity of antiprotons, e.g., linearity, or any\nantiprotons. I don't think there are any such effects but they should be able to demonstrate\nphenomena that would cause non-linear or threshold effects based on the quantity of\nGeneral\n18) Estimate the margin of error in any calculations or experimental data you provide.\n19) Provide references used and details on any computer codes used to provide information\nrelevant to these issues, and any verification and validation performed.\n20) Provide details on the credentials and backgrounds of personnel involved in providing\ninformation relevant to the issues, including peer reviewers. I realize that I will have to be\nhelp DOT on this, I will recuse myself from assisting Jackson unless you see this different.\ncareful here as G. Jackson might come back to me on this! Since I have already agreed to\n21) Provide any test data that substantiates calculated data, or of any physical testing that is\nplanned to be conducted to corroborate any calculated data.\nShould you have further questions on this matter, please contact Mr. Jim Williams, Office of\nHazardous Materials Technology, (202) 366-4545.\nSincerely,\nAssociate Administrator for\nRobert A. McGuire\nHazardous Material Safety","truncated":false,"body_characters":16486}