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Re: Shipping Questions
(1) See NRC Information Notice 92-62, "Emergency Response Information Requirements for Radioactive Material Shipments." The NRC has tested licensee compliance with this requirement. I've heard that, in some cases, they had inspectors stop shipments as they left a facility. The inspector then called the emergency response number to see whether the
required information was available. Two items of interest in the IN: (a) "... Emergency responders will expect the licensee to remain on the line until the information needed has been provided. Emergency responders will also expect this information within 15 minutes." Thus, it is generally not acceptable that the person who answers the emergency
number have to contact someone at home. (b) "Licensees may also wish to note that the Chemical Transportation Emergency Center (CHEMTREC) will provide and monitor the 24-hour emergency response telephone number for a fee..." Another possibility is that some carriers will provide this service. In my organization, our control room phone number is
used. To assure that the operating staff has the required information, we provide the control room a copy of the shipping paper and the applicable page from the "Emergency Response Guide." To meet the 15 minute requirement, we generally require that this information be in the control room within 10 minutes of the shipment being released. (This can
be accomplished by fax.)
(2) Type A packages are a perennial problem. One widespread misunderstanding is that all you need is a "certification" from the package vendor. RTFR: 49 CFR 173.415: "...Each offeror of a Specification 7A package must maintain on file for at least one year after the latest shipment, and shall provide to DOT on request, complete documentation of
tests and an engineering evaluation or comparative data ..." I've had trouble obtaining this information from vendors who think that a simple, "trust me, it's 7A" letter is sufficient. Another pitfall is that the "package" includes both the packaging and the contents. It's important to see what contents were tested and determine whether your
contents are within the test envelope; eg, packaging that has been tested as "Type A" for solids is not necessarily good for liquid. Self testing of packaging would be difficult unless you have a suitable test facility. Vendors are available, but "caveat emptor." Another possibility is to use the Hanford test data, available at:
http://www.hanford.gov/pss/t&p/dot7a/pdot7a.htm
If you can obtain packaging which meets the specs of what was tested, and your contents are within the test envelope, you can use this documentation.
Another possibility, if you are sending packages by air, is to use the IATA specs. Vendors are available who supply kits for specific types of shipments. They advertise in the IATA rules books.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Joey Michael wrote:
> DOT 172.604 requires an emergency response telephone number. It says that the person answering the phone must be "either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who has such knowledge and information."
>
> What is your interpretation of the knowledge level required by the person answering the phone? This would be for a radioactive materials white I or yellow II package. Is having the info out of the DOT response guide enough or should the person be an HP (or HP Tech.)? How do other universities handle this requirement?
>
> My second question has to do with type 7A packaging. Since no one sells 'certified' boxes, do you test your own, have it tested by someone else. In other words how have others found to solve this problem?
>
> You may respond to me directly.
>
> Thank You,
>
> Joey Michael
> mailto:joey-michael@uiowa.edu
> University of Iowa
> Health Protection Office
>
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