DOT, "Advance notice of proposed rulemaking"

[William V Lipton <liptonw@dteenergy.com>]

In a "Federal Register" notice of December 28, 1999, DOT-RSPA requested
comments on a proposal to revise the hazardous materials transport
regulations, based on a recent change to the IAEA Safety Standards, as
reflected in IAEA Publication No. ST-1, "Regulations for the Safe
Transport of Radioactive Material - 1996 Edition."  "Comments are
requested from interested persons concerning the scope of the NPRM,
i.e., extent to which differences between the HMR and the IAEA
publication ST-1 should be considered in proposing changes to the HMR."
Comments are due by March 29, 2000.

Sorry for the late notice.  To develop meaningful comments, you'll have
to obtain a copy of ST-1.  (I ordered this on the date of the notice,
and it arrived, yesterday.)  The notice includes information on how to
obtain ST-1.  Here are some of the potential changes.

Scope:  ST-1 clarifies the scope of the transport regulations,
specifically excluding:  "(a) radioactive material that is an integral
part of the means of transport;"  [I've run across this when shipping
material in a depleted uranium cask.  This explicitly excludes the cask
material from the shipping papers.] ... (d) radioactive material in
consumer products which have received regulatory approval, following
their sale to the end user; ..." [This will obviate the perennial
question of how to ship smoke detectors, gun sights, and similar items.]

nuclide specific thresholds - ST-1 replaces the blanket 2 nCi/g
threshold for "radioactive material" with nuclide specific thresholds.
These seem to be lower than 2 nCi/g for many of the radionuclides of
interest.

changes to A1 and A2 values - Some of the values are changed; mostly
higher.  For example, these values seem to increase by a factor of 5 for
transuranics.  We should look at our key radionuclides to seem if any of
the changes would change the type of shipment.

new proper shipping names and identification numbers:  the psn's would
be a lot more specific, eg., "Radioactive Material, Type A Package,
non-special form, non fissile or fissile excepted."  "NOS" goes away.
There would be 25 separate psn's, not including psn's that include
incidental radioactivity, such as thorium nitrate and uranyl nitrate.  I
don't see this as a major problem.

UN identification numbers would be required on all packages, including
excepted packages.

The criticality transport index is being replaced with a "criticality
safety index."  The transport index would hence be based solely on the 1
meter dose rate.

There would be special requirements for UF6 packages.

There would be a new, "Type C" package, in conjunction with activity
limits for Type B packages transported by air.

Some of the package testing requirements have been changed.  My concern,
here, is that some packages may have to be retested and may be unusable
if they cannot pass the new tests.

All of this is at a preliminary stage.  Now's the time to get involved.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com




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