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CTMA 2015 HM-250 and HM-215M Update

This update highlights the Final Rule HM-250 and HM-215M that harmonize international standards for non-radioactive and radioactive material transportation. It covers scope, definitions, limited quantity, packaging, marking, overpacks, labels, and shipping papers.

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CTMA 2015 HM-250 and HM-215M Update

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  1. CTMA 2015HM-250 and HM-215M Update Regulatory Changes from DOT

  2. 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

  3. HM-250 HM-215M Final Rule that harmonizes with the international standards (ICAO and IMDG) mainly for non-radioactive requirements Which is Which? • Final Rule that primarily harmonizes with 2009 IAEA TS-R-1 for the transportation of radioactive materials

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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)

  9. 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)

  10. 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)

  11. Type A Packaging • 173.412(f) pressure changed from 25 kPa (3.6 psi) to 60 kPa (8.7 psia)

  12. 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. 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. 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. 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. 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. Excepted Package Marking173.422(a)(2) • RQ for any non-bulk excepted package containing a hazardous substance

  18. 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. 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. Radioactive Label • Maximum activity of the radioactive contents during transport 172.403(g)(2)

  21. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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 required

  32. 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/decontaminated

  33. 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. 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. Definitions 171.8 • New or revised • Absorbed gas • Bundle of cylinders • Large salvage packaging • Neutron radiation detector • Non-bulk packaging • Radiation detection system

  36. 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. 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. 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. Special Provisions172.102 • Safety devices (automotive parts) • Neutron Detectors • Absorbed gases • Paint/paint related material in same package • Uranium Hexafluoride • IBC Codes

  40. Shipper’s Certification • Above = Below “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.

  41. 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. Explosives Table of Packing Methods • Changes to some packing methods • Always consult the table

  43. 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

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