November/December 2004

NEW DOT REGULATIONS:
LSA SHIPMENTS NEED SPECIAL HANDLING
by Kurt Colborn

Q&A: DOT’S REGULATORY HARMONIZATION

“Exempt shipments will be rarer; more will be LSA”

Last month, the U.S. Department of Transportation (DOT), working with the U.S. Nuclear Regulatory Commission, began implementing new regulations governing how low-level radioactive waste must be classified, packaged and transported. We asked Kurt Colborn, MHF Logistical Solutions director of technical services, for the details.

Q: What’s behind the new regulations?
A: Basically, the DOT has harmonized regulations in the U.S. with those from the International Atomic Energy Agency that are followed in many other countries. That’s important for the industry in the U.S. as it will allow us more easily to work internationally.

Q: What are the key elements of the new regulations?
A: There are a number of bullet points. First, there’s a new definition of what constitutes “radioactive materials” and with that, new exemption criteria for what does not need to be treated as radioactive material. Also, there are new packaging requirements and new rules about how shipments are to be marked and classified.

Q: Can you explain the new definition of what constitutes ‘radioactive materials’?
A: Sure. Previously, DOT fixed activity levels below which materials were not considered to be radioactive. That approach was not based on risk but on arbitrary standards. The dividing line was set at 2,000 picocuries per gram of total activity. Anything below that was not considered radioactive and was exempt from most regulation. Anything above that 2,000 threshold was regulated and required special handling. Now DOT has adopted an isotope-specific measuring process, one that takes into account risk-based analysis of specific materials. Now we have to look at each isotope, and compare the quantity of each radionuclide present to regulatory limits on activity concentration and the total activity of the consignment.

Q: Sounds like the whole system has become more complicated.
A: Yes it has. Determining exempt quantities is decidedly more complex now.

Q: And packaging?
A: “Strong Tight” packaging no longer exists, and shippers are less likely to be able to ship materials as “unpackaged” in the new regulations. The new regulations will move many shippers to select “IP-1” packaging. “IP” stands for “Industrial Packaging.” Incidentally, we’ve recently upgraded the certification of our Super Load Wrappers™ to address the new regulations. The Super Load Wrappers, which are used in bulk gondola railcars, are now IP-1 compliant, which means that rail can continue to be used for shipping low-level radioactive waste. There are a number of new rules about marking and labeling that shippers in the field need to understand.

Q: Who is most impacted by the new regulations?
A: Well, just about everybody in the nuclear and low-level radioactivity shipping business. But, the impact is not evenly spread. Some remediation projects are hard hit because their large quantities that had been exempt now fall under the more stringent regulations. But really, everyone will feel this one way or another. The bottom line is that exempt-shipments will be rarer and more will be LSA, or “Low Specific Acitivity.”

Q: Are people in the industry aware of the new regulations?
A: Yes, most are. But, some may not be aware of all the ramifications. There are a lot of subtleties.

Q: Are companies prepared?
A: All I can say about that is that we’ve done our best to make sure that our clients are.

Got a question about the new DOT technical regulations or other technical issues? You can reach Kurt Colborn at kurt_colborn@mhfls.com or 724.772.9800 ext. 5560.