Interpretation Response #14-0242
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 17, 2015
Celia Rajkovich, RRPT
Radiation Health Physicist
Bureau of Radiation Protection
Southwest Regional Office
400 Waterfront Drive
Pittsburgh, PA 15222
Ref. No. 14-0242
Dear Ms. Rajkovich:
This responds to your December 17, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for interpretation on completing a shipping paper when transporting a Radioactive Yellow-III labeled package placed inside a Yellow-II labeled rigid overpack.
At the request of a member of my staff, you provided the following additional information about the Yellow-III labeled package: it contains a radiography camera with 150 Curies of solid metal Ir-192, UN 2916 special form. You also indicate the camera is in its own package, Type B(U), which weighs 50 pounds. The radioactive dose level on the camera is 55 mrem with a transport index (TI) of 2. Finally, the package is packed in a rigid overpack (ammo box) at the Yellow-II level (i.e., equal to or less than 50 mrem and a transport index ( TI) less than 1).
For a Class 7 radioactive material, § 172.202(a) of the HMR requires the description of the hazardous material on the shipping paper to include the UN identification number, the proper shipping name, the hazard class, the total quantity by activity of material covered by the description, and the number and type of packages. Note the proper shipping name does not need to be repeated, however, the number of packages (i.e., one) needs to be included.
Section 172.203(c) requires additional information for hazardous substances. Specifically, for a radionuclide that is a hazardous substance based on exceeding the reportable quantity listed in Table 2 to Appendix A of § 172.102, the letters "RQ" must be included before or after the basic description. It is our understanding that 150 Curies exceeds the reportable quantity for Ir-192, thus, the shipping paper must include the letters "RQ."
Section 172.203(d) requires additional radioactive material information to be included on the shipping paper depending on the circumstances of the shipment. Based on our understanding of your situation, § 172.203(d) requires the name of the radionuclide, the activity in SI units (and may include customary units in parentheses) contained in the package, the category label, and the TI assigned to the package to be included on the shipping paper. However, we recommend that you review § 172.203(d)(1)-(10) to ensure all required information is included. For instance, for an export shipment you may be subject to a notation of the International Atomic Energy Agency package identification marking. Note also that § 172.202(a)(5) requires the total quantity by activity in applicable units whereas § 172.203(d) requires the activity per package in SI units. Because you are shipping only one package, you need not repeat the activity as part of the description.
Therefore, based on the information you provided, the following would be an example of an acceptable shipping description on the shipping paper:
1, RQ, UN 2916, Radioactive material, Type B(U) package, 7, 5.55 TBq (150 Ci), Ir-192, Radioactive Yellow-II, and TI=2.
Finally, the labeling information required for the overpack under § 172.403(h) is not required to be included on the shipping paper.
I hope this answers your inquiry. If you need additional assistance, please call this Office at 202-366-8553.
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
172.202(a), 172.203(c), 172.203(d), 172.203(d)(1)-(10), 172.202(a)(5), 172.403(h)
|§ 172.403||Class 7 (radioactive) material|