CTMA 2015HM-250 and HM-215M Update

Regulatory Changes from DOT

T1504003.

Dates to Remember

• Final Rule HM-250

– Published on July 11, 2014

– Effective Date: October 1, 2014

– Delayed Compliance Date: July 13, 2015

• Final Rule HM-215M

– Published on January 8, 2015

– Effective Date: January 1, 2015

– Delayed Compliance Date: January 1, 2016

2

T1504003.

Which is Which?

HM-250

• Final Rule that primarily harmonizes with 2009 IAEA TS-R-1 for the transportation of radioactive materials

HM-215M

• Final Rule that harmonizes with the international standards (ICAO and IMDG) mainly for non-radioactive requirements

3

T1504003.

173.401(b)(4) and (5)

• Scope

When is radioactive material not Class 7?

– Modified language in paragraph (b)(4) concerning naturally occurring radionuclides

– Added a new paragraph (b)(5) establishing that objects with contamination are not regulated if levels do not exceed the definition of contamination in 173.403

4

T1504003.

Definitions in 173.403

• Contamination – minor wording changes

• Criticality Safety Index – added “conveyance”

• Exclusive Use – can only use when required

• Fissile Material – clarified and added reference to the exceptions in 173.453

5

T1504003.

Definitions in 173.403

• Low Specific Activity

– Mainly revised for clarity• Non-fissile or fissile excepted in the opening paragraph

• Radiation Level

– Clarifies that it is the sum of all types of ionizing radiation present

6

T1504003.

173.433

• Revisions to the requirements for calculating A1 and A2 values for unlisted radionuclides

– Added “or no relevant data…” in (b) to help us with using the Tables

– Rewording of (c) has some unintended consequences

– Corrected references for symbols in (d)

– Radioactive contents in Table 7 has been reworded to more closely align with the TS-R-1

7

T1504003.

Limited Quantity 173.421

• Formatting changes: re-designation of the paragraphs

– Unfortunately these are not properly referenced in the following sections:

• SP 369

• 173.4(b)

• 173.423(a)(2)

• 173.426(c)

• 173.428(a)

8

T1504003.

New Proper Shipping Name

• UN3507 Uranium Hexafluoride, Radioactive Material, excepted package Class 8 (7)

– Only for 0.1 kg or less Uranium Hexafluoride

– Must meet the requirements for Ltd. Qty. 173.421

– Ripple effects:

• Addition of Special Provision 369

• Minor changes to 173.2a

• Changes to 173.420(d)

9

T1504003.

Packaging

• General Design Requirements in 173.410

– For air shipments, internal pressure differential is not less than maximum normal operating pressure + 95 kPa

• Industrial Packages in 173.411

– Clarifies the use of portable tanks in (b)(4)

– Clarifies the use of cargo tank/tank car in (b)(5)

– Revised 1 year document retention to 2 years in (c)

10

T1504003.

Type A Packaging

• 173.412(f) pressure changed from 25 kPa (3.6 psi) to 60 kPa (8.7 psia)

11

T1504003. 12

T1504003.

Type A Packaging

• 173.415(a)

– Revision of the document retention period from 1 year to 2 years (after January 1, 2017)

– Rewritten to describe (at length) the two options for document retention

• Full description of packaging and testing or

• Certification from the packaging manufacturer

13

T1504003.

LSA/SCO Transport Requirements173.427(a)

• For Exclusive Use LSA/SCO 173.427(a)(6)

– The “shipment” must be placarded (instead of the “transport vehicle”)

– Removed the placarding exception for uranium and thorium ores

– Subsidiary hazard labels required (even though primary label is not)

14

T1504003.

LSA/SCO Transport Requirements 173.427(b)

• Paragraph (b)(5)– Portable Tanks, Cargo Tanks, Tank Cars meeting the requirements

for Type IP-1 can be used as Type IP-2 or Type IP-3 (173.411)

– Not limited to LSA-I liquids

– No longer required to be exclusive use

– References to DOT tanks removed

15

T1504003.

LSA/SCO Transport Requirements 173.427(c)

• Paragraph (c)(4)

– New paragraph requiring placarding for all unpackaged LSA-I/SCO-I by highway and rail

16

T1504003.

LSA/SCO Transport Requirements 173.427 Tables

• Table 5

– New third column for inland waterway conveyance limits

• Table 6

– Added “Type” to all IP descriptions

17

T1504003.

Excepted Package Marking173.422(a)(2)

• RQ for any non-bulk excepted package containing a hazardous substance

18

T1504003.

Specification Marking172.310(b)

• Package Type

– Marking size requirement 12mm (0.47 inches)

• Type IP-1, Type IP-2, Type IP-3

• Type A

• Type B(U), Type B(M)

19

T1504003.

173.25 Overpack

• HM-250 added that overpacks containing radioactive packages must be marked with the word “OVERPACK”

• HM-215M removed the radioactive packages (inadvertently?) but added a minimum size requirement of 12mm (0.5 inches) high

20

T1504003.

Radioactive Label

• Maximum activity of the radioactive contents during transport 172.403(g)(2)

21

T1504003.

LSA/SCO Subsidiary Label

• Although excepted from radioactive labels (for the primary hazard), LSA/SCO exclusive use must be labeled for any subsidiary hazards per 173.427(a)(6)(vi)

– Ripple effect: subsidiary hazard will now be required as a shipping paper entry

22

T1504003.

Shipping Papers

• 172.203(d) Additional description requirements

– “Special Form” if not already in the proper shipping name

– Maximum activity of the radioactive contents during transport

– Label category does not require “RADIOACTIVE”

23

T1504003.

172.504 Placarding

• Radioactive placards are required on

– Packages with Yellow-III labels

– All shipments of unpackaged LSA-I/SCO-I

– All exclusive use shipments in 173.427

– All exclusive use shipments in 173.441

– All exclusive use shipments in 173.457

– Closed vehicles used in accordance with 173.443(d)

24

T1504003.

Contamination Control173.443

• This section previously addressed only external contamination on a package

• Now included is the external surface on a– Package

– Conveyance

– Freight container

– Overpack

• Plus the internal surfaces when used to transport inner packages

25

T1504003.

Contamination Control173.443 (a)

• All contamination must be kept As Low As Reasonably Achievable (ALARA)

• Levels may not exceed Table 9 EXCEPT for– Equipment dedicated to transport unpackaged material in

accordance with 173.427(c) and

– Remain under that specific exclusive use

• Non-exclusive use shipments are not required to be surveyed unless contamination is suspected

26

T1504003.

Contamination Control173.443 (a) and (b)

• Table 9 Limits: Corrected the conversion from bq/cm2 to dpm/cm2 using SI units instead of customary units

• Reworded (b): Still allows for 10 times Table 9 limits during transport and must be exclusive use (“weeping” condition)

27

T1504003.

Contamination Control173.443 (c)

• Each conveyance, overpack, freight container, tank or IBC used as exclusive use under the following conditions must be surveyed with appropriate radiation detection instruments after each shipment:

– 173.443(b) the “weeping” condition

– 173.427(b)(4) LSA/SCO, <A2, in excepted packaging

– 173.427(c) unpackaged LSA-I and SCO-I

28

T1504003.

Contamination Control173.443(c)

• The survey must show that non-fixed contamination meets 173.443(a)

– ALARA

– Does not exceed Table 9 limits

• The radiation level at each accessible surface is ≤ 0.5 mrem/hr

29

T1504003.

Contamination Control173.443(c)

• Meeting these survey requirements ONLY allows for continued exclusive use of the equipment as one of the following:

– 173.443(b) the “weeping” condition

– 173.427(b)(4) LSA/SCO, <A2, in excepted packaging

– 173.427(c) unpackaged LSA-I and SCO-I

30

T1504003.

Contamination Control173.443(c)

• The ONLY way to utilize the aforementioned exclusive use shipment types for non-exclusive use or general service is:

– Perform decon on the equipment as necessary and

– Any contamination is determined to be below the limits in 173.401(b)(5) and below the definition of contamination in 173.403

31

T1504003.

Contamination Control173.443(d)

• “Sole Use” allows up to 10 times the Table 9 limits for vehicles used under the following conditions– Exclusive use by highway or rail

– Survey of interior surfaces of empty vehicle• ≤ 10 mrem/hr surface

• ≤ 2 mrem/hr at 1 meter

– “For Radioactive Materials Use Only” stenciled

– Kept closed (except for loading and unloading)

– Placards required32

T1504003.

Contamination Control 173.443(e)

• New paragraph for leaking or suspect packages– Restrict access

– Assessment of the contamination must include• The package

• The conveyance

• Adjacent loading/unloading areas

• All other materials carried on the conveyance

– Protect persons, property, environment

– Not forwarded until repaired/decontaminated33

T1504003.

Contamination Control

• Added similar language for surveys and re-use to all modes of transport

– Carriage by Rail in 174.715

– Carriage by Aircraft in 175.705

– Carriage by Vessel in 176.715

– Carriage by Public Highway in 177.843

34

T1504003.

HM-215M : “Timing is Everything”

• Important to note:

– Because this rule was published AFTER October 1, 2014 it is not in the current 49 CFR (unless you use regulations that are updated quarterly)

– This Final Rule must be consulted in addition to the current 49 CFR if you are complying with HM-215 in 2015 and especially after January 1, 2016

35

T1504003.

Definitions 171.8

• New or revised

– Absorbed gas

– Bundle of cylinders

– Large salvage packaging

– Neutron radiation detector

– Non-bulk packaging

– Radiation detection system

36

T1504003.

171.23(b)(11)

• Requirements for specific materials transported under ICAO, IMDG, TDG or IAEA

– Fissile excepted materials must meet IAEA SSR-6 regulations and 173.453

37

T1504003.

Proper Shipping Names

• Ten shipping names were removed

• Dozens have been added

• Pages and pages of entries were revised

– Largely due to changes in Column 10 for IMDG harmony

38

T1504003.

List of Marine Pollutants

• Addition of 62 new entries

• New exception for 5 liters (liquids) and 5 kg (solids) if regulated only because they are a marine pollutant

39

T1504003.

Special Provisions172.102

• Safety devices (automotive parts)

• Neutron Detectors

• Absorbed gases

• Paint/paint related material in same package

• Uranium Hexafluoride

• IBC Codes

40

T1504003.

Shipper’s Certification

• Above = Below

41

“This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.”

Note: In the certification the word “above” may be

substituted for the word “below” as appropriate.

T1504003.

Exceptions for Light Bulbs173.11

• No other requirements if:

– 1 g or less of hazardous material per bulb

– 30 g or less of hazardous material per package

– Each bulb in separate inner packaging

– Strong tight outer (173.24(b))

– Capable of passing a 1.2 m (4 foot) drop test

42

T1504003.

Explosives Table of Packing Methods

• Changes to some packing methods

– Always consult the table

43

T1504003.

Lithium Cells and Batteries173.185

• Added Large Packaging requirements

• Allows for the Cargo Aircraft Only Label to substitute for the lithium battery marking

44

Questions?

Thank You

45