hazardous materials regulations

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

This is a reminder to RADSAFER's that the due date for comments on
proposed changes to the hazardous materials regulations (HMR) is June
29, 2000.  (See the "Federal Register"  notice of December 28, 1999 for
"advance notice of proposed rulemaking."  The original deadline of March
29, 2000 was extended in a "Federal Register" notice of March 1, 2000.)

The proposed rulemaking would achieve compatability with the new IAEA
guidance, ST-1.

Summarizing my thoughts on this -

I like:

ST-1 has scope limitations which exclude consumer commodities, such as
smoke detectors, and radioactive material that is an integral part of
packaging, from the HMR.

ST-1 removes criticality safety considerations from the definition of
the "Transport Index."  There would be a separate "Criticality Safety
Index," and the Transport Index would be based solely on the 1 meter
dose rate.

In general, A1 and A2 values increase.

I don't like:

The current regulatory threshold for "radioactive material" of 2 nCi/g
specific activity is replaced by radionuclide-specific concentration and
total consignment quantity limits.  In general, the concentration limits
are less than 2 nCi/g.

Current NRC/DOT guidance, in NUREG-1608/RAMREG-003, "Categorizing and
Transporting Low Specific Activity Material and Surface Contaminated
Objects," sets a regulatory threshold for nonradioactive objects with
surface contamination.  This is NOT included in ST-1.

The requirements for a "Radiation Protection Program," which originally
appeared in the last major revision of the HMR but was removed, appear
in ST-1.  This imposes requirements  to control dose to the public from
material in transit.  It is unclear how a shipper could assure that such
limits are met.  This seems to be an unreasonable burden, since I am not
aware of any cases involving excessive radiation exposure to members of
the public from radioactive material being shipped in compliance with
the HMR.

The proposed removable contamination limits on packages are increased
by an order of magnitude.  I don't like this, since there is no problem
meeting the current limits, and an increase would create an unreasonable
risk of residual contamination in transport vehicles and would create
contamination control problems for the receiver.

The proposed changes to the UN numbers and Proper Shipping Names would
be costly to implement while providing little, if any, benefit.

Since package testing is costly and time consuming, any changes to
package testing specifications should include a provision exempting
currently certified packaging from the new requirements.

I encourage RADSAFER's to submit comments both as individuals and on
behalf of their employers.

Send me a private e-mail if you'd like help with your comments
submission.

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

Bill Lipton
liptonw@dteenergy.com


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