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Transportation FAQs (Generator Site Access):
Waste Management and Radiation Control Permits and Permitting

Since, September 9, 2001, Jule Fausto, Health Physicist, has conducted preliminary safety inspections at the Envirocare of Utah, low-level waste disposal facility. These FAQs are based on observations and findings to date.

Permit Requirements

Do carriers or transporters of radioactive waste for disposal within the state of Utah have to obtain a generator site access permit?

No, as stated in Utah R303-26-3 only generators or brokers shall obtain a Generator Site Access Permit from the Executive Secretary before transferring radioactive waste to a land disposal facility in Utah, shippers are considered carriers not Generator Site Access permittees.

How are “Broker” activities defined under the Generator Site Access Permit Program criteria?

A “Broker” means a person who performs one or more of the following functions for a generator: arranges transportation of the radioactive waste; collects or consolidates shipments of radioactive waste; or processes radioactive waste in some manner.

Are generators required to provide a copy of the “Uniform Low Level Radioactive Waste Manifest” for shipments consigned for disposal within Utah?

Yes, Generator Site Access permittee’s are required to provide a copy of the manifest prior to arriving but not more than thirty days prior to shipment departures.

Shipping Papers

Can an electronic version of the waste manifest information be provided?

Yes, however a physical copy of the electronic manifest bearing the signature of the generator must accompany the waste during transportation. Copies of the manifest must be dated by, and bear the handwritten signature of the person representing the generator of the waste, each subsequent carrier accepting the waste, and the designated facility receiving the waste.

What is an appropriate shipping description for hazardous substance shipments that meet the reporting threshold requirements listed in the 49 CFR Table 1 to Appendix A?

If the proper shipping name does not identify the name of the hazardous substance, it must be entered in parenthesis in association with the basic description and the letters “RQ” shall be entered on the shipping paper either before or after the basic description. For example: “RQ, Environmentally hazardous substances, solid, nos, 9, UN3077, III, (PCB’s).

Marking

What are the requirements for marking large quantities of radioactive material in a non-bulk package?

Unless emptied, each package is to be marked with the following:

  1. Proper shipping name and identification number.
  2. The aggregate gross weight of the hazardous materials
  3. Technical names of hazardous substances, and the letters “RQ” in associations with the description.
  4. Exempted packages must be marked with the “DOT-E” followed by the exemption number.
  5. Each package must have the consignee or consignor name and address.
  6. If the package contains low specific activity (LSA) material it must be stenciled or marked “Radioactive-LSA”, if it is a surface contaminated object (SCO) it must be stenciled or marked with “Radioactive-SCO.”

Labeling

Do all packages of waste have to be labeled to identify the class of waste?

Yes, each package of waste must be clearly labeled, identifying whether it is a Class A waste, Class B waste, or Class C waste.

Placarding

Are slogans or signs, such as “Drive Safely”, which are often displayed on placards or in placard holders, prohibited on a transport vehicle and freight container?

Yes. Any slogan, sign, or other device that by its color, design, shape, or content, could be confused with any placard is prohibited.

Do all transport vehicles containing radioactive materials have to display “Radioactive” placards?

No, shipments of unconcentrated uranium or thorium ores do not.

Emergency Response Information

Question: Does the Emergency Response Guidebook (ERG) “guide number” that applies to a hazardous material have to be shown on a shipping paper?

No, the ERG “guide number” does not need to be on the shipping paper. If the carrier uses the ERG to fulfill the emergency response information requirements, the proper shipping name and UN ID number are acceptable to cross reference the correct entry in the ERG.

Training

May a hazardous material employer/employee train and test themselves?

Yes, self-training is acceptable provided that all training requirements of 172.704 are met.

Who is responsible to certify that the hazardous material employee is trained and tested?

The hazardous material employer is responsible to meet training requirements and to determine certification.

Stenciling

Are railcars containing radioactive materials required to be marked with the car initial and number?

Yes, the reporting mark and the car number, are to be stenciled, or otherwise displayed, in clearly legible letters and numbers not less than seven inches high on each side or each railroad freight car body.

Load Restraint

What would constitute adequate load restraint?

Each package containing a hazardous material being transported must be loaded so that it cannot fall or slide and must be safeguarded in such a manner that other freight cannot fall onto or slide into it under conditions normally incident to transportation. When other freight cannot be provided to protect against movement, blocking and bracing must be provided. Publications are provided as example and reference information resources such as the Bureau of Explosive Pamphlet Nos. 6 and 6C and Association of American Railroads, Circular-43-A.