[ RadSafe ] Changes in DOT HazMat regs for Boron Triflouride gas in Neutron Detectors

Capt. Bruce Bugg obbugg at gsp.net
Mon Jan 7 13:03:39 CST 2013

Not sure how many people this might affect, certainly anyone who has to ship a detector by UPS, FedEx or some other air carrier.

The full rulemaking notice will be in  the Monday, January 7, Federal register:

The relevant text on Neutron detectors is below. The rule is retroactive to January 1, 2013.

"The entry for UN1008 Boron trifluoride is assigned new special
provision 238. See Section 172.102 Special provisions for a detailed
discussion of the addition of special provision 238."

Discussion in the preamble to the rule:

"Special provision 238 is added to address the shipment of neutron
radiation detectors. Neutron detection is a key component used in
nuclear arms interdiction in addition to other applications such as
nuclear reactor monitoring, neutron-based cancer treatments, neutron
spallation, nondestructive testing and health physics applications.
Most neutron radiation detectors contain boron trifluoride gas, UN1008,
which is currently forbidden by passenger and cargo aircraft as noted
in Columns (9A) and (9B) of the HMT. Currently, neutron radiation
detectors that contain this gas can only be transported by air under a
special permit.
    "ICAO recently adopted a special provision specifically addressing
neutron radiation detectors. The recently adopted special provision
A190 permits, under certain conditions the transportation by cargo
aircraft of neutron radiation detectors containing boron trifluoride.
These conditions include quantity of gas limitations, and construction
and packaging specifications. The special provision also provides that
under certain conditions these neutron radiation detectors containing
not more than 1 gram of boron trifluoride gas are not otherwise subject
to the ICAO Technical Instructions.
    "PHMSA granted a special permit, for the transportation by all
modes, of certain neutron radiation detectors containing boron
trifluoride gas. The limitations set forth in Special Provision A190 of
the ICAO Technical Instructions do not exceed any limitations of the
special permit and, therefore, PHMSA is adopting and applying them to
all modes of transportation except passenger-carrying aircraft by
incorporating them into Sec.  172.102(c)(1), Special provision 238.
Specifically, the special provision provides packaging requirements
(including pressure limitations), quantities permitted, and package
construction requirements for radiation detectors containing non-
pressurized boron trifluoride gas in excess of 1 gram.
                "The special provision also provides additional exceptions from the HMR based on the
transport mode and other conditions. The special provision will be
applicable to the entry ``UN1008, Boron trifluoride'' in the HMT. PHMSA
believes the adoption of this special provision provides an adequate
level of safety for the transportation of these items, while providing
flexibility in the need to obtain a special permit."

Actual text of the new Special Provision:

238 Neutron radiation detectors:
    a. Neutron radiation detectors containing non-pressurized boron
trifluoride gas in excess of 1 gram and radiation detection systems
containing such neutron radiation detectors as components may be
transported by highway, rail, vessel, or cargo aircraft in accordance
with the following:
    (1) The pressure in each neutron radiation detector must not exceed
105 kPa absolute at 20 [deg]C;
    (2) The amount of gas must not exceed 12.8 grams per detector and
the amount per outer packaging or per radiation detection system must
not exceed 51.2 grams;
    (3) Each neutron radiation detector must be of welded metal
construction with brazed metal to ceramic feed through assemblies. They
must have a minimum burst pressure of 1800 kPa; and
    (4) Each neutron radiation detector must be packed in a sealed
intermediate plastic liner with sufficient absorbent material to absorb
the entire gas contents. Neutron radiation detectors must be packed in
strong outer packagings that are capable of withstanding a 1.8 meter
(6-foot) drop without leakage. Radiation detection systems containing
neutron radiation detectors must also include absorbent material
sufficient to absorb the entire gas contents of the neutron radiation
detectors. Absorbent material must be surrounded by a liner or liners,
as appropriate. They must be packed in strong outer packagings unless
neutron radiation detectors are afforded equivalent protection by the
radiation detection system.
    b. Except for transportation by aircraft, neutron radiation
detectors and radiation detection systems containing such detectors transported in
accordance with paragraph (a) of this special provision are not subject
to the labeling and placarding requirements of part 172 of this
    c. When transported by highway, rail, vessel, or as cargo on an
aircraft, neutron radiation detectors containing not more than 1 gram
of boron trifluoride, including those with solder glass joints, and
radiation detection systems containing such detectors, where the
neutron radiation detectors meet and are packed in accordance with the
requirements of paragraph (a) of this special provision, are not
subject to any other requirements of this subchapter.

Capt. Bruce Bugg #7013
Region 3 Commander
Motor Carrier Compliance Division
Georgia Department of Public Safety
320 Chester Avenue, SE
Atlanta, GA  30316
phone:              (404) 463-3880
voicemail:         (404) 463-3899
fax:                   (770) 357-8867
email:               obbugg[at]gsp.net (replace "[at]" with @)

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