Re: Empty radioactive material shipping packages

[Ninni Jacob <njacob@gsosun1.gso.uri.edu>]

NOTE: I am sending this to RADSAFE since it may be of general interest. 

On Wed, 8 May 1996, Slaback@micf.nist.gov wrote:

> DoT has a specific hazardous material
> category for shipping 'empty' shipping
> containers.  
> If the container is absolutely clean does
> this regulation apply? 

Les, I attended a transportation seminar recently, and what I learned was
that "empty" does not mean "cleaned".
According to 173.428:
" A package which previously contained Class 7 (radioactive) materials and
has been emptied of its contents as far as practical, is excepted from the
shipping paper and certification, marking and labelling requirements etc, "

It has to have en "EMPTY" label on it.
However, It has to meet the packaging requirements of 173.422.


) That is, is it
> hazardous material even if it is not
> radioactive? 

As far as I can tell from the regs, it is only for radioactive.

> If you had a virgin, 20 ton Type B cask tied 
> to a truck bed would you would you omit the
> empty cask identification and shipping papers?

I would say "Yes".

 
> If the answer to the above is negative, how
> contaminated would it have to be to necessitate
> labeling as an empty container?
 
The answer is positive , ie you could omit the empty cask identification
and shipping papers. The only criteria to label it as "EMPTY" seems to be
if it had carried radioactive material and was not cleaned.

But if you were shipping it as "Empty" the contamination levels have to be
below the limits specified in 173.421, which are:
a)the radiation level at any point on external surface must be less than 0.5
mrem/hour
b)the removable contamination must be less than 22dpm/sq.cm beta-gamma,
and 2.2dpm/sq.cm alpha

I hope that helps.
Ninni Jacob
Radiation Safety Officer
University of Rhode Island/
Rhode Island Nuclear Science Center
16 Reactor Road
Narragansett,RI 02882

Phone: (401) 789-9391
Fax:   (401) 782-4201
email: njacob@gsosun1.gso.uri.edu