This section provides a brief overview of the hazardous material (HAZMAT) regulatory requirements for transporting nuclear gauges. TheTroxler Transportation Guide contains more detailed information, including sample shipping papers and other documentation.
The regulations governing the transportation of nuclear gauges are contained in Title 49 of the Code of Federal Regulations. Please refer to those regulations for complete details of transportation requirements. The following information summarizes some of the main requirements applicable to shippers of nuclear gauges.
It is the responsibility of any person transporting a nuclear gauge to ensure that proper precautions are taken to prevent the theft of the gauge. Some commonsense suggestions and a security checklist can be found under Homeland Security on our website. To further enhance the security of gauges during transport Troxler also offers a special Mounted Transportation Box.
CERTIFICATE OF COMPETENT AUTHORITY
A copy of the IAEA Certificate of Competent Authority (sometimes referred to as “Special Form Certificate”) must be on file for at least one year after the latest shipment of a nuclear gauge. You can download a copy from our web site. Please note that these certificates have expiration dates.
NOTE: The sources in some older Troxler gauges are no longer certified as Special Form because of the manufacture date. These sources may be subject to shipping restrictions or may require that you modify your shipping practices. Please refer to the Special Gauge Shipping Instructions for further details.
TYPE A PACKAGE TESTING RESULTS
A copy of the results of Type A package testing for the shipping case must be on file for at least two years after the latest shipment. This information can be found in the Troxler Transportation Guide.
A certificate of training must be on file for each individual who transports or prepares a nuclear gauge for transport. Troxler’s Nuclear Gauge Safety Training course covers transportation requirements for nuclear gauges. Periodic Hazmat refresher training is required every 3 years.
MARKING AND LABELING
The package must be marked with the proper shipping name and labeled on opposite sides. Most Troxler transport cases require the Yellow II label which must denote the radionuclide, activity, and transport index. In addition, Type A packages must be labeled “US DOT 7A Type A”.
EMERGENCY RESPONSE INFORMATION
Emergency response information must accompany each shipment of a nuclear gauge. The document containing this information must be immediately accessible to the driver at all times during transportation on a public highway. A 24-hour emergency response telephone number must be listed on the shipping papers. Troxler provides this service to Troxler gauge users at no charge. The emergency response phone number is:
Whenever a nuclear gauge is shipped or transported it must be accompanied by properly completed shipping papers. Please consult the Troxler Transportation Guide for details. When transported via highway a properly completed bill of lading must be in the transport vehicle and immediately accessible to the driver.
SEALING OF PACKAGE
Each Type A package must contain a seal that is not readily breakable and provides evidence that the package has not been opened in transit. This seal is required when transporting a gauge to and from a work site, as well as when shipping the gauge by a common carrier (e.g., FedEx).
INSPECTION PRIOR TO SHIPMENT
Before transporting a nuclear gauge, the shipper must inspect the package (shipping case) to ensure it is in good physical condition other than superficial marks and that all closure devices are in good working order and secured.
Emergency Radiation Procedures
These emergency instructions apply whenever a nuclear gauge is involved in an event that might cause damage to the source or its shielding or prevent the return of the source to the shielded position (e.g. when the gauge is struck by a piece of equipment, is contained in a vehicle involved in an accident, or involved in a fire).
GAUGE USER OR OPERATOR
Immediately cordon off the area around the gauge (approximately 15 foot radius) and prevent unauthorized personnel from entering the area to minimize personnel exposure. The gauge operator should stand by outside the cordoned area and maintain constant surveillance of the gauge until emergency response personnel arrive.
Detain any equipment or vehicle involved in the accident and the operator until it is determined that no contamination is present. Gauge users and other potentially contaminated personnel should not leave the scene until they have been checked for contamination by emergency response personnel.
Notify appropriate emergency response personnel (e.g. the licensee’s Radiation Safety Officer, NRC or State officials) as soon as possible.
RSO AND LICENSEE MANAGEMENT
Evaluate the condition of the gauge. Determine if the source(s) are present and if they are in the shielded position (if applicable). If the source(s) are out of the gauge they must be located immediately.
Arrange for a radiation survey to be conducted as soon as possible by a knowledgeable person using appropriate radiation detection instrumentation. This person could be a licensee employee or a consultant competent in the use of radiation survey meters. The Troxler gauge operation manual contains a radiation profile chart which gives the normal radiation levels near the gauge. The radiation survey readings can be compared to the radiation profile for the gauge contained in the gauge operation manual to determine if the readings are normal.
Make necessary notifications to local authorities as well as the NRC as required. Even if not required to do so, you may report any incident to the NRC by calling NRC’s Emergency Operations Center at 1.301.816.5100, which is staffed 24 hours a day and accepts collect calls. NRC or Agreement State notification is required when gauges containing licensed material are lost or stolen, when gauges are damaged or involved in incidents that result in doses in excess of 10 CFR 20.2203 limits, and when it becomes apparent that attempts to recover a source stuck below the surface will be unsuccessful. NRC reporting requirements and time frames are found in 10 CFR 20.2201-2203.
RETURNING DAMAGED GAUGES TO TROXLER
When it is necessary to return a gauge that has been damaged to Troxler for repair or disposal, the following procedure must be followed.
Conduct a standard wipe test of the gauge to verify the sources are not leaking and provide the test results to Troxler.
Send photographs showing the damage, especially damage affecting the shielding of the radioactive sources, to the attention of the Troxler RSO. If the damage is extensive or the gauge cannot be shipped in the original shipping case, Troxler will provide assistance or directions for packaging and shipment.
Upon review of the leak test results and photographs by the Troxler RSO, a Returned Goods Authorization (RGA) number will be issued for return of the gauge to Troxler.