Training/Guide on Shipping NORM/Rad Contaminated Items

[Jokenessmonster]

Didn't know where else to post this.  Does anyone have a link on a good guide on how to properly ship NORM/Rad contaminated shipments?  We might be picking up a contract to ship contaminated oilfield equipment (pipes and rods) to a waste facility.  Is it possible to do so knowing only the surface readings?  I looked at the materials and it doesn't look like I can easily obtain samples for lab testing in order to find out the exact concentration (pCi/g) of various radionuclides.  Here in the oilfield we usually see Ra 226, Ra 228, and Pb 210. Any help is greatly appreciated! 

[GLW]

Before taking umbrage just read through this;

If you do not already know the answers you are not qualified to do the work.

I consider 49 CFR to be one of the best examples of how the government should hold people accountable for what they do because 49 CFR lays out all the rules and pretty much puts all the responsibility for getting it right on the shipper.

If you are wrong (illegal) and they do not catch you,... no harm no foul (to you).

If you are wrong and they do catch you, then you own it,... you own the fines, the jail time, the whole nine yards.

And there is a lot to it and no one should ever trust their freedom from accountability up to and including jail time to some dribs and drabs they read on an internet blog.

You need to hire a qualified consultant and/or broker.

And/or you need to acquire the function specific training for yourself so you will then know what you do know, and you can then recognize what you do not know;.....

i.e. [49 CFR (and the others) is (are) a very big book(s)].

Once in commerce, your packaged or unpackaged materials will stop at the same stop signs as school buses full of preschoolers, and your trains will pass by and through neighborhoods and playgrounds.

It's not doomsday stuff, but it is a field of endeavour where you are either legal, or you are not legal.

You need to hire a qualified consultant and/or broker.

to answer you question,...here's a link to your guide:

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title49/49tab_02.tpl

you will note it is titled PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

YMWV,...enjoy the day,...

almost forgot,....(sic) 4 beercort,....

[Jokenessmonster]

Don't get mad, but thanks for the help Capt. Obvious.

I have looked at the 49 CFR and had specific questions about shipping tubulars.

The 40hr RSO course I attended, when it came to shipping, stated "you'll probably be working in a lab or large facility that has a designated shipping department that will know all the rules.  If you have any questions ask them or look it up in the 49 CFR."  It's obvious I don't work in such a facility.  Despite my many protests the VP assumes that because of this training I know all there is about radiation.  I have already shot him down on several things because they were either unsafe, or violated our radiation license. 

I have called PHMSA and all they did was inform me that our waste is TENORM not NORM, which I already knew.  That was it.  Bureaucracy at it's finest.

Finally, I agree on getting the training.  That is why "training" is part of my thread title. 

Thanks.

[GLW]

Don't get mad, but thanks for the help Capt. Obvious.

I have looked at the 49 CFR and had specific questions about shipping tubulars.

The 40hr RSO course I attended, when it came to shipping, stated "you'll probably be working in a lab or large facility that has a designated shipping department that will know all the rules.  If you have any questions ask them or look it up in the 49 CFR."  It's obvious I don't work in such a facility.  Despite my many protests the VP assumes that because of this training I know all there is about radiation.  I have already shot him down on several things because they were either unsafe, or violated our radiation license. 

I have called PHMSA and all they did was inform me that our waste is TENORM not NORM, which I already knew.  That was it.  Bureaucracy at it's finest.

Finally, I agree on getting the training.  That is why "training" is part of my thread title. 

Thanks.

Call TMGI (there are others too),...

Want your tubulars to ship out?,...ask me for a quote, cut me a PO, and I'll ship 'em for ya,....

I'm qualified,...

Or ask any of my qualified associates and colleagues, I know lots of 'em, we all know each other,...

PM me and I'll get back to you,...

When it comes time to help specific people with specific questions I stick to PMs and I prefer POs,...

Have you ever read through the blogs at RADSAFE?!?,...

* Smart People #1 poses a question,...

* Smart Guy B gives his assessment,...

* Smart Gal D throws in a caveat,...

* 116 posts of caveats, what ifs, OBTWs and "don't forgets" later the thread has answered about half of the OPs question but nobody cares anymore because they already got in their two cents of  specific self worth proving minutae and now the world knows just how smart everybody else is,....

boooooooooooooooooooooooooooring,... 

I do not give out a lot of technical over blog pages, too easy for someone to get set up for failure, then you get the nasty PM from some sad panda about how you never mentioned scenario A, B, C or D and how you screwed said panda,...

And the above post is not just for you because it's an open forum, so other people, less astute than yourself, may surmise that whatever they read here is all there is to it,...

I like people to appreciate just how much is involved with being good at what we do, and appreciate that expertise should be paid for at market value,...

So I tend to stick to platitudes and direction pointing, not specifics, because most posters to blogs are not down for all the specifics and details,...

And that's where the devil lives,...

I'm just saying,...

[GLW]

....I have called PHMSA and all they did was inform me that our waste is TENORM not NORM, which I already knew.  That was it.  Bureaucracy at it's finest.....

And that is not fair to PHMSA,...

they are regulators,...not trainers,...

when you call them for interpretation there is a format and protocol for acquiring and disseminating those interpretations,...

they are not a "how to or how do I" training resource,...

again, I'm just saying,...

[Jokenessmonster]

And that is not fair to PHMSA,...

they are regulators,...not trainers,...

when you call them for interpretation there is a format and protocol for acquiring and disseminating those interpretations,...

they are not a "how to or how do I" training resource,...

again, I'm just saying,...

I understand that, but if I ask them about a specific scenario and if I do "a" is "a" legal I'd expect a yes or no answer.  They'll damn sure fine if I do it wrong.

You're second post was much more informative, thanks.  It reaffirmed my initial belief that one shouldn't waste their time asking questions on an internet forum, even one filled with "intellectuals."  Just saying.

[GLW]

I understand that, but if I ask them about a specific scenario and if I do "a" is "a" legal I'd expect a yes or no answer.  They'll damn sure fine if I do it wrong.

that's the down side to 49 CFR and the folks at PHMSA reflect that downside,...

49 CFR is not user friendly and is not an easy read,...

as for me?!?!?!,... I relish the challenge, it's what I live for (as far as work goes),....

[Marlin]

I understand that, but if I ask them about a specific scenario and if I do "a" is "a" legal I'd expect a yes or no answer.  They'll damn sure fine if I do it wrong.

You're second post was much more informative, thanks.  It reaffirmed my initial belief that one shouldn't waste their time asking questions on an internet forum, even one filled with "intellectuals."  Just saying.

   I have had the training to ship Hazardous mixed waste several times over the last over the last few decades and have shipped a large quantity of waste. I do not consider myself a shipper (Broker) because of the complexity at times (fissile is a b@#$%h) if I haven't shipped for six months to a year I feel like I am starting all over again. GLW gave you some very good advice from a practical not academic point of view. Mistakes can shut you down, a penalty more expensive than fines when it is for an extended period of time.
   If your initial belief was that this site was a waste of time why are you here? This site has posters from a very broad range of people from entry level to managers to regulators. Having a open but skeptical attitude is productive having an adversarial attitude is not.

[Chimera]

You're second post was much more informative, thanks.  It reaffirmed my initial belief that one shouldn't waste their time asking questions on an internet forum, even one filled with "intellectuals."  Just saying.

Your "just saying" tells me you took the wrong message from the advice furnished above.  You were given good info from two of the heaviest hitters on this site.  No, they're not going to give you a quick answer to a complicated question in the one or two paragraphs you seem to have been looking for.  But you now know how to contact two very knowledgeable individuals to possibly give you further assistance.

Ain't none of us in here "intellectuals".  Most of us learned our craft the hard way - personal experience coupled with the occasional mentor and a lot of personal "hit the books" time.  Some learn better than others.

[GLW]

Your "just saying" tells me you took the wrong message from the advice furnished above.  You were given good info from two of the heaviest hitters on this site.  No, they're not going to give you a quick answer to a complicated question in the one or two paragraphs you seem to have been looking for.  But you now know how to contact two very knowledgeable individuals to possibly give you further assistance.

Ain't none of us in here "intellectuals".  Most of us learned our craft the hard way - personal experience coupled with the occasional mentor and a lot of personal "hit the books" time.  Some learn better than others.

I have to think we are reading too much into the OPs dialogue,...

I don't see the same thing, the OP is responding just fine, he's just not gettin' all humble, and I'm good with it, we're just airing it out here, no disrespect given, none taken,...

[spentfuel]

Perhaps this may help

http://www.tenorm.com/regs2.htm

Not sure the answer to your question is there or not but perhaps

sf

[Marlin]

I have to think we are reading too much into the OPs dialogue,...

I don't see the same thing, the OP is responding just fine, he's just not gettin' all humble, and I'm good with it, we're just airing it out here, no disrespect given, none taken,...

Don't get mad, but thanks for the help Capt. Obvious.

You're second post was much more informative, thanks.  It reaffirmed my initial belief that one shouldn't waste their time asking questions on an internet forum, even one filled with "intellectuals."  Just saying.

Perhaps, it may be a lack of experience or expertise on this kind of forum.

[Jokenessmonster]

I have to think we are reading too much into the OPs dialogue,...

I don't see the same thing, the OP is responding just fine, he's just not gettin' all humble, and I'm good with it, we're just airing it out here, no disrespect given, none taken,...

Exactly.  As for the humble part, am I not humbling myself by posting and asking for help?  The main subject mentions training and/or guide.  I am admitting I need training.  While I did post part of my particular situation I wasn't expecting a spoon fed answer.  

While you all were typing and posting about being offended I was on the phone with U.S. Ecology who not only answered my questions (can SCO-1 be wrapped in plastic and duct taped and how to characterize waste if you don't have an analysis to work with, only readings), but also gave me the names of 2 places where I can go to get in depth training.  Our company doesn't ship rad waste, but we do decon TENORM contaminated equipment which generates rad waste (catch 22).  Generally it is PPE, rags and some scale or water.  Those are easily drummed in DOT approved drums.  Not only that, but the waste is small enough to be sent to a lab to be tested, wherein I can use the results to figure out the UN#, etc.  The tubulars are posing me with a different problem.  Which is why I posted here.  A simple link as to where to go/sign up for proper training would have sufficed.

I respect the fact that you guys have more knowledge and experience than, that's why I joined in the first place.  On any other given day I would have just shrugged off some of the responses. However, I've spent the last few days fighting with our VP as to what's legal and what's not according to our radiation license (of which I am knowledgable about) and am in no mood for people to point out the obvious that I'm not qualified/knowledgable when it comes to shipping rad waste.

[spentfuel]

Also from 49CFR173.401

(b) This subpart does not apply to:

ect then there is (4)

(4) Natural material and ores containing naturally occurring radionuclides which are either in their natural state, or which have only been processed for purposes other than for extraction of the radionuclides, and which are not intended to be processed for the use of these radionuclides, provided the activity concentration of the material does not exceed 10 times the exempt material activity concentration values specified in §173.436, or determined in accordance with the requirements of §173.433.

sf

[Marlin]

I've spent the last few days fighting with our VP as to what's legal and what's not according to our radiation license (of which I am knowledgable about) and am in no mood for people to point out the obvious that I'm not qualified/knowledgable when it comes to shipping rad waste.

So you bring that to an open forum while asking for help? The internet does not allow for nonverbal communication on mood other than emoticons, attention to perception of your message should change from that of face to face interaction.

Just Say'n    

[Jokenessmonster]

I didn't initially bring anything to the forum other than a question.  I asked a simple question and got, what I perceived to be, an internet troll answer and responded in kind.  He juked, I ducked, now we're good.  It's everyone else that's hurt now. 

Just sayin'.

[Jokenessmonster]

Also from 49CFR173.401

(b) This subpart does not apply to:

ect then there is (4)

(4) Natural material and ores containing naturally occurring radionuclides which are either in their natural state, or which have only been processed for purposes other than for extraction of the radionuclides, and which are not intended to be processed for the use of these radionuclides, provided the activity concentration of the material does not exceed 10 times the exempt material activity concentration values specified in §173.436, or determined in accordance with the requirements of §173.433.

sf

Thank you for the help!  The PHMSA has ruled that that exemption doesn't apply to us though.  The following is a link to their letter of interpretation:
http://phmsa.dot.gov/pv_obj_cache/pv_obj_id_8C01D0DAB56FACCA278444DE4C69446DC8BE0000/filename/130157.pdf

[The NORM Lady!]

Since this original post is from a few months back, the opportunity for the contract may have passed, or the work may have been completed. Hopefully this information will be useful regardless. This response is provided for informational purposes only and is considered professional advice, as not all pertinent information has been provided in this forum for your particular situation/project, nor are all scenarios explored.

Making the determinations on whether or not the pipe and rods are considered radioactive per 49 CFR DOT regulations can be intimidating if you have not received proper training. From the sound of the 40-hour RSO course you attended as described, it must not have been specific to NORM/TENORM and if it was, then it did not sufficiently provide you with the information to ship Class 7 radioactive material loads for NORM/TENORM. I offer an 8-hour Transportation of NORM/TENORM course, in which we cover the Class 7 regulations as they pertain to NORM/TENORM specifically. It is taught from a "how to" perspective. Our website lists courses and contains my credentials and qualifications (Geri Blanchard) if you are interested in checking it out www.normsolutions.com/about-us/. My other site www.tenorm.com, also contains information regarding NORM/TENORM that you may find valuable, which someone has already provided a link to you in the earlier posts.

In regards to your question, you need to determine whether the waste contaminating the pipe and rods is considered radioactive per DOT. These calculations require laboratory data, which you will probably prefer in pCi/g for Ra226, Ra228, Th228 and Pb210. For the oil and gas industry, including the petrochemical sector, the combination of radionuclides depends on whether your waste stream is from oil/wet gas/water or dry gas processing, as you are not using all four radionuclides at once. If you are unsure as to which product stream the contamination results from, then you would evaluate the lab data for the highest concentrations, and use the combination which is most representative for the waste stream. We can speak privately if you have additional questions on this.

49 CFR does provide you the option of a choosing a tentative shipping category, which allows for the choosing a shipping category based on your knowledge of the material. This is not recommended unless an emergency response situation or other immediate action is necessary. There is an opportunity that your TENORM-contamination may not exceed the exemption limits in 49 CFR 173.436, in which the regulations will not apply. A sample is critical for this step, and since the pipe and rods have minimal scale visible to collect, you have a few other options for obtaining the sample:

1. Perform a wipe test for removable surface contamination and send the smear/swipe to the laboratory for results in pCi/g.
2. Removing a small piece of metal that represents the equipment, and send it to the lab for results in pCi/g.
3. If the equipment is being actively decontaminated, collect air samples and send them to the lab for results in pCi/g. Gross alpha and beta analysis for air samples typically report in µCi/mL, so make sure the lab knows to convert to pCi/g. It is not a difficult conversion, but why not have them list the results in pCi/g on the report to save you time.

It is correct that DOT has responded with letters of interpretation stating that TENORM does not utilize the 49 CFR 173.401(b)(4) 10X exemption for the Exempt Activity Concentration Limit, which is provided to NORM. TENORM it has been enhanced by technical means. The most recent DOT response letter stating this decision dated January 20, 2015, was specifically addressing oil and gas TENORM from flowback and produced water wastes.

If you need more information on appropriate labs, methods, etc. feel free to contact me. The fact that your 40-hr RSO course (if it was indeed a NORM/TENORM course), did not provide this information to you, was a disservice to you, and should have covered this. Subscribing to our newsletter for additional, complimentary real-world information on NORM/TENORM may pose useful to you as well.