{"operation":"document","citation":"14-0242","title":"Bureau of Radiation Protection — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-06-17","effective_on":null,"summary":"14-0242 response to Bureau of Radiation Protection concerning 172.202, 172.203, 172.403.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0242.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0242.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0242","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/140242.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue st\nWashington, DC 20590\nPipeline and Hazardous\nAdministration\nMaterials Safety\nJUN 1 7 2015\nCelia Rajkovich, RRPT\nRadiation Health Physicist\nBureau of Radiation Protection\nSouthwest Regional Office\n400 Waterfront Drive\nPittsburgh, PA 15222\nRef. No. 14-0242\nDear Ms. Rajkovich:\nThis responds to your December 17, 2014 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for\ninterpretation on completing a shipping paper when transporting a Radioactive Yellow-III\nlabeled package placed inside a Yellow-II labeled rigid overpack.\nAt the request of a member of my staff, you provided the following additional information\nabout the Yellow-III labeled package: it contains a radiography camera with 150 Curies of\nsolid metal Ir-192, UN 2916 special form. You also indicate the camera is in its own\npackage, Type B(U), which weighs 50 pounds. The radiation level on the camera is 55\nmrem/hr with a transport index (TI) of 2. Finally, the package is packed in a rigid overpack\n(ammo box) at the Yellow-II level (i.e., equal to or less than 50 mrem/hr and a transport\nindex (TI) not more than 1).\nFor a Class 7 radioactive material, § 172.202(a) of the HMR requires the description of the\nhazardous material on the shipping paper to include the UN identification number, the\nproper shipping name, the hazard class, the total quantity by activity of material covered by\nthe description, and the number and type of packages. Note that because the package type is\npart of the proper shipping name it need not be repeated but only the number included (i.e.,\none).\nSection 172.203(c) requires additional information for hazardous substances. Specifically,\nfor a radionuclide that is a hazardous substance based on exceeding the reportable quantity\nlisted in Table 2 to Appendix A of § 172.102, the letters \"RQ\" must be included before or\nafter the basic description. It is our understanding that 150 Curies exceeds the reportable\nquantity for Ir-192, thus, the shipping paper must include the letters \"RQ.\"\n1\n\n<<<PAGE 2>>>\n\nSection 172.203(d) requires additional radioactive material information to be included on\nthe shipping paper depending on the circumstances of the shipment. Based on our\nunderstanding of your situation, § 172.203(d) requires the name of the radionuclide, the\nactivity in SI units (and may include customary units in parentheses) contained in the\npackage, the category label, and the TI assigned to the package to be included on the\nshipping paper. However, we recommend that you review § 172.203(d)(1)-(10) to ensure\nall required information is included. For instance, for an export shipment you may be\nsubject to a notation of the International Atomic Energy Agency package identification\nmarking. Note also that § 172.202(a)(5) requires the total quantity by activity in applicable\nunits whereas § 172.203(d) requires the activity per package in SI units. Because you are\nshipping only one package, you need not repeat the activity as part of the description.\nTherefore, based on the information for the radiography camera scenario you provided, the\nfollowing would be examples of an acceptable shipping description on the shipping paper:\n1, RQ, UN 2916, Radioactive material, Type B(U) package, 7, Ir-192, 5.55 TBq (150 Ci),\nRadioactive Yellow-III, and TI=2\nor\n1, RQ, UN 2916, Radioactive material, Type B(U) package, 7, Ir-192, 5.55 TBq (150 Ci),\nRadioactive Yellow-Il, and TI= [Where X was not specified in the information you\nprovided but was stated as being less than 1].\nIn the first example, the labeling information required for the overpack under § 172.403(h)\nis not required to be included on the shipping paper.\nPlease note the reasoning for selection of the Yellow-II and TI of less than 1 notation on the\nshipping paper in the second example is as follows. Although § 172.203(d)(4) and (5)\nrequires the category of label and the transport index assigned to each package in the\nshipment bearing Yellow-II or Yellow-III labels, the definition of package in § 173.403\nmeans the packaging together with its radioactive contents as presented for transport. In\nyour example, the package has been overpacked when presented for transport and due to\nsome shielding and increased distance provided by the overpack, the radiation levels outside\nthe overpack are also appropriate values to use to convey the external radiological hazard\nduring routine transport. However, it should also be noted that the individual package(s)\nwithin an overpack must still be labeled appropriately, so as to convey hazard\ncommunications such as in the event of a possible incident or partial unloading scenario.\nTherefore, in the example you provided, the overpack would be labeled as Yellow-Il in\naccordance with § 172.403(h)(3) and (4) and, because § 172.403(h)(5) mandates placarding\nbased on the aforementioned overpack labeling, then the shipping paper description could\nbe based on the overpack labeling as well so as to provide consistent hazard\ncommunications throughout and reduce the possibility of frustration of the shipment. We\nrecognize that the use of the overpack radiation levels is not as readily apparent from a\nhuman factors perspective as it perhaps could be in § 172.203(d)(4) and (5), which do not\n\n<<<PAGE 3>>>\n\nspecifically cite \"overpack\" in addition to \"package\" at present, and we may clarify the\nrequirement in a future rulemaking.\nI hope this answers your inquiry. If you need additional assistance, please call this Office at\n202-366-8553.\nSincerely,\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 4>>>\n\nBoothe\n§172.202\nshippin\nPapere\nDodd, Alice (PHMSA)\nFrom:\nCiccarone, Michael CTR (PHMSA)\nSent:\nWednesday, December 17, 2014 4:51 PM\nTo:\nHazmat Interps\nSubject:\nFW: seeking a letter of interpretation for radioactive material transportation\nShante/Alice,\nPlease submit this for a formal letter of interpretation. Ms. Rajkovich spoke with Shelby in the HMIC.\nThanks,\nMike\n----Original Message--.\nFrom: Rajkovich, Celia [mailto:craikovich@pa.gov]\nSent: Wednesday, December 17, 2014 2:22 PM\nTo: PHMSA HM InfoCenter\nSubject: seeking a letter of interpretation for radioactive material transportation\nTo: U.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nI am seeking a letter of interpretation in regard to completion of shipping papers when transporting a Class 7\nRadioactive Yellow III Labeled package (such as a radiography camera) inside a Yellow Il labeled rigid over pack. Please\nadvice of the correct complete wording on the shipping paper.\nThank you for your time,\nCelia Rajkovich, RRPT\nRadiation Health Physicist\nBureau of Radiation Protection\nSouthwest Regional Office\n400 Waterfront Drive\nPittsburgh, PA 15222-4745\nv 412-442-4222 F 412-442-5246\nwww.depweb.state.pa.us\n\n<<<PAGE 5>>>\n\n14-0242\nemail\n13531/54\nIr 192150 Curies\nSolid Metal\nhAM special Form VN3332\nUSA Type B Package camera in its oun factoge\n50 pounds\nras levér on camera 55 mrem\nTE=2\nY TH\nin rigid overfacts (ammo bes) Yuered sent\noutside ammo box somiem 55 45\nno placards on dentisoon pictap tracts\nUN3332, Radioactive material, Toge A peckage,\nSpecies farm, 7,\nmen finnie a fissile erased\n173,415\n173,474 (d)","truncated":false,"body_characters":7328}