Harmonization - Two Years' of Transportation Regulation Lessons Learned
- MHF Logistical Solutions, Cranberry Township, PA (United States)
The U.S. Department of Transportation issued modifications to the Hazardous Materials Regulations in October, 2004 as part of an ongoing effort to 'harmonize' U.S. regulations with those of the International Atomic Energy Agency. The harmonization effort had several predictable effects on low level radioactive materials shipment that were anticipated even prior to their implementation. However, after two years' experience with the new regulations, transporters have identified several effects on transportation which were not entirely apparent when the regulations were first implemented. This paper presents several case studies in the transportation of low level radioactive materials since the harmonization rules took effect. In each case, an analysis of the challenge posed by the regulatory revision is provided. In some cases, more than one strategy for compliance was considered, and the advantages and disadvantages of each are discussed. In several cases, regulatory interpretations were sought and obtained, and these are presented to clarify the legitimacy of the compliance approach. The presentation of interpretations will be accompanied by reports of clarifying discussions with the U.S. DOT about the interpretation and scope of the regulatory change. Specific transportation issues raised by the revised hazardous materials regulations are reviewed, including: The new definition of radioactive material in accordance with isotope-specific concentration and total activity limits. The new hazardous materials regulations (HMR) created a new definition for radioactive material. A case study is presented for soils contaminated with low levels of Th-230. These soils had been being shipped for years as exempt material under the old 2,000 pCi/g concentration limit. Under the new HMR, these same soils were radioactive material. Further, in rail-car quantities their activity exceeded an A2 value, so shipment of the material in gondolas appeared to require an IP-2 package. Interpretations, discussions, and an exemption were obtained to secure the continued shipment of this material. A provision to allow 'natural' radioactive materials to be exempt from the requirements of the HMR at up to 10x the listed isotopic concentrations. The revised HMR exempts certain natural materials and ores from regulation as radioactive material at concentrations up to 10x that allowed if the materials are not natural. The term 'natural' is not well defined, and initial attempts to qualify for this exemption were thwarted by concerns over what degree of material processing, if any, materials could experience and still be considered 'natural'. The presentation includes an example from a project involving post-processed tungsten ore, and includes interpretations from the US DOT as well as clarifying language from current and drafted IAEA regulation and guidance. New packaging descriptions allowing the use of cargo containers as IP-2 and IP-3 packages in some applications. The revised HMR provides an alternate certification procedure under which standard cargo containers can be used as IP-2 and IP-3 containers. There has been some confusion about how this high level of certification can apply to standard cargo containers when other sections of the regulations make this certification available only to considerably more stout containers after rigorous testing. The discussion includes interpretive guidance from the US DOT, and from the UK Department of Transport clarifying the same provision in IAEA regulations. A new definition of contamination with apparently broad impact on the shipment of empty containers and conveyances. The revised HMR presented a definition of contamination not referenced by any other part of the HMR. The preamble to the revised HMR provides confusing guidance on the application of the definition to shipment of empty containers, and subsequent interpretive guidance letters appear to conflict with the preamble as well as with each other. The definition also has the effect of regulating materials for transport as radioactive even when US NRC and US Department of Energy (DOE) guidance documents suggest that the materials are free-releasable. This presentation provides the latest available information on this emerging issue. The presentation strives to provide the benefit of recent real-world experience in new aspects of the HMR. The examples provides should have broad application to shippers of a variety of low level radioactive materials in the US and internationally. (authors)
- Research Organization:
- WM Symposia, 1628 E. Southern Avenue, Suite 9 - 332, Tempe, AZ 85282 (United States)
- OSTI ID:
- 21294707
- Report Number(s):
- INIS-US-09-WM-07344; TRN: US10V0234040897
- Resource Relation:
- Conference: WM'07: 2007 Waste Management Symposium - Global Accomplishments in Environmental and Radioactive Waste Management: Education and Opportunity for the Next Generation of Waste Management Professionals, Tucson, AZ (United States), 25 Feb - 1 Mar 2007; Other Information: Country of input: France
- Country of Publication:
- United States
- Language:
- English
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