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.
This section provides a brief overview of the hazardous material (HAZMAT) regulatory requirements for transporting nuclear gauges. The Troxler 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.
Special Gauge Shipping Instructions
(For gauges with sources that are not Special Form)
Some older model gauges contain sources which are no longer certified as Special Form. The table below shows the source codes and serial number ranges that are affected and whether the sources can be shipped alternatively as Normal Form in a Type A package or can be shipped under a Special Permit.
|Source Code||Affected Source S/N||Nuclide||Ship as Normal Form or Special Permit|
|CC, 40||<4552||Cs-137||Normal Form|
|CA, CAA, 47||<740||Am-241||Special Permit|
17978 & 18080
|75||Between 1296 & 1395||Cs-137||Normal Form|
Radioactive material which is not certified as Special Form is referred to as “Normal Form.” The standard shipping instructions are based on the assumption that both sources in a gauge are Special Form. When one or both of the sources are Normal Form, the standard instructions are no longer valid.
Am-241 sources that are not certified as Special Form cannot be shipped as Normal Form. However, Troxler has been granted a Special Permit that authorizes one-time shipment of these sources for disposal only. The Special Permit imposes a number of conditions and requirements on the shipper. Troxler has prepared an information package that fully describes these conditions and provides shipping instructions. Please contact Troxler Customer Service or the Radiation Safety Department to obtain the package. Do not ship any gauge until you receive a Return Goods Authorization (RGA) number from Troxler.
A gauge may be shipped if just the Cs-137 or Ra-226 source is not certified as Special Form (i.e., Normal Form), but package markings, shipping papers, and emergency response instructions must be modified.The following sections explain the modifications necessary to ship a 3400 series gauge in which the Cs-137 is Normal Form and the Am-241 is Special Form.
When the Cs-137 source is Normal Form the standard shipping case label must be labeled as shown below. The first line describes the type of packaging, the second line describes the Special Form Am-241 source, and the third line describes the Normal Form Cs-137 source. The type on the label must be at least 0.5 inches high.
USA DOT 7A TYPE A
RADIOACTIVE MATERIAL, TYPE A PACKAGE, SPECIAL FORM, UN3332, RQ
RADIOACTIVE MATERIAL, TYPE A PACKAGE, UN2915
When the Cs-137 source is Normal Form the dangerous good description on the shipping papers must be modified to list the proper shipping names and UN ID numbers for both Normal Form (Cs-137) and Special Form (Am-241) materials. In addition, nuclide and activity, the physical and chemical form must be identified for Normal Form material.
Emergency Response Sheets
When the Cs-137 source is Normal Form, two different emergency response information sheets must accompany the shipment: one for the Normal Form material (UN2915) and one for the Special Form material (UN3332).
Example of the new emergency response information sheet for Normal Form Radioactive Material.(UN2915)
If you have any questions about whether the sources in a Troxler gauge are certified as Special Form or about the instructions for shipping a gauge that contains both Normal Form and Special Form material, please contact the Troxler Radiation Safety Department.
Licensing Nuclear Gauges
OBTAINING A LICENSE
Individuals or organizations desiring to possess and use portable nuclear gauges must obtain a license issued by the applicable regulatory agency. In the U.S., the Nuclear Regulatory Commission (NRC) has jurisdiction over the licensing and regulation of radioactive material. However, under agreement with the NRC, thirty-three states (so-called Agreement States) have assumed responsibility for issuing licensing and enforcing radiation protection regulations within their borders. The NRC requires Agreement State regulations to be compatible with (although not necessarily identical to) NRC regulations. Detailed guidance on preparing NRC or Agreement State license applications is contained in the Troxler Licensing Guide. For information regarding sealed source and device (SS&D) registration sheets, click here.
Licensees must request amendments to their licenses whenever the information originally submitted is no longer valid or they wish to make a change that affects the license. In general, license amendments must be submitted and approved before making the requested change, e.g., changing the location of the licensed activities or acquiring licensed materials not listed on the license. The licensing agency should be notified of any changes in personnel listed on the license as soon as possible.
Radioactive materials licenses have expiration dates and must be periodically renewed. If a licensee submits a renewal application at least 30 days before the expiration date, the license is automatically extended until the regulatory agency acts upon the application. If this is done, the license is referred to as being “under timely renewal.”
In general, Agreement States will recognize and honor a valid license issued by another state or the NRC. The NRC in turn recognizes licenses issued by Agreement States. This is referred to as reciprocal recognition or reciprocity. Typically, a state will allow an out-of-state licensee to conduct licensed activities for between 30 and 365 days, but most typically 180 days, in a calendar year under reciprocity. To conduct activities for more days than permitted under reciprocity, a specific license must be obtained in that state. All states require at least a 3-day advance notice, a copy of a valid license, and submission of information about the nature, location, and dates of the proposed activities before authorizing licensed activities under reciprocity. Most states also require payment of a reciprocity fee. See the Agreement State table for a listing of fees and links to state web sites where more information can be obtained. Click here for reciprocity information by state.
Special Form Certificates
The serial number for each source has a two- or three-digit prefix that is associated with a special form certificate (as shown in the table below). For example, a source with serial number 75-2345 (prefix 75) is associated with special form certificate USA/0614/S-96.
The special form certificates are available in Adobe Acrobat 3.0 format.
Some of the values in the Source Serial Number Prefix column flagged with an asterisk (*) may no longer be considered special form materials. Visit the Special Gauge Shipping page for more information.
|Source Serial Number Prefix||Nuclide||Activity mCi||Special Form Certificate||Expiration Date||view|
|CC*||Cs-137||8||USA/0673/S-96 Revision 5 (replaces GB/140/S)||6/30/2028||view|
|82||Co-60||0.06||USA 0733 S-96
* Visit the Special Gauge Shipping page for more information.
Homeland Security & Your Nuclear Gauge
Homeland Security is on the minds of everyone these days. Undoubtedly you have read stories in the newspapers or watched reports on television about the possibility of radioactive materials being used for illicit purposes. The sources in portable gauges are sealed in stainless steel capsules that would be difficult to breach and cause radioactive contamination. Further, the relatively small amount of radioactive material would not represent a major hazard if spread over a large area.
However, during the period from January 1996 to October 2000 there were 156 reported thefts of nuclear gauges according to statistics maintained by the U.S. Nuclear Regulatory Commission. Only 40% of the stolen gauges were ever recovered. Most of the thefts occurred while gauges were stored in vehicles parked in areas away from the work site, often when the vehicle was parked at a private residence. NRC’s analysis indicates that many gauges were stolen from trucks even when the gauges were secured with chains. Frequently, the gauges were locked in an open truck bed, readily visible to the public. Sometimes the entire vehicle was stolen along with the gauge. Because of the heightened concern about homeland security, all nuclear gauge thefts are being turned over to the FBI for investigation.
What can you do to keep your gauge more secure during transport and field operations, to avoid regulatory violations and fines, and to stay out the headlines? Here are some common sense suggestions:
- Maintain control and constant visual surveillance of nuclear gauges. This is the most fundamental responsibility of the gauge operator. Things can happen to gauges when you turn your back or leave a gauge unattended – even for a few moments.
- Reduce the visibility of the gauge. Transport the gauge inside a closed vehicle, inside a tool box, or under a cargo cover to reduce visibility. A bright yellow box with a big chain in the back of an open truck calls attention to itself as something valuable – something worth stealing. Furthermore, chains are easily and quickly cut.
- Require gauges to be locked inside closed or covered vehicle compartments or lock boxes. Many types and styles of steel lock boxes are available that can be bolted directly to the vehicle and locked. In addition to reducing visibility, these lock boxes provide greater security than a chain. Troxler is now offering a mounted transportation box made specifically for our gauges.
- Do not park vehicles in areas vulnerable to theft.
- Never leave the keys inside a vehicle when the vehicle is unattended.
- Use a steering wheel lock when the vehicle is parked. In some cases, preventing the theft of the vehicle is the key to preventing the loss of a portable gauge.
- Store the gauge at a permanent or temporary storage facility whenever the gauge is not in use. Your permanent storage location is listed on your license. A temporary storage facility may also be established at a job site, e.g., a locked room or trailer. You should make sure that any storage location is very secure. All radiation protection rules must be followed as well, e.g., posting the area with Caution Radioactive Material signs.
- Hold special gauge user training to increase awareness of security. Make sure that all personnel are aware of and understand the proper procedures for the physical security of gauges. It is a good idea to hold a session with all gauge operators at the beginning of each construction season and review your company’s security procedures.
- Conduct spot checks or inspections of operators in the field. Hold operators accountable and perform spot checks to make sure that security procedures are being followed.
For further information, see these recent information NRC information notices:
If you have any ideas on this subject, we would be interested in hearing about them. Please e-mail us to tell how you maintain security during transportation of your gauge.
Sealed Source & Device Registration Sheets
The Sealed Source and Device (SS&D) registration sheet for various Troxler gauges are listed below. To view a sheet, click on the registration number.
TLD Badge Services
Troxler provides dosimetry badge service for personnel who work with radioactive materials or equipment that produces ionizing radiation. The TLD badges offered by Troxler detect and monitor beta, gamma, X-ray and neutron radiation. Our badges are processed by a NVLAP-accredited laboratory (NVLAP lab code 100555-0).
If you are a new customer, we will ship your badges within about 7-10 days of receipt of your order. You will receive an invoice at the beginning of the following quarter that the service began. Change requests will be processed promptly and your account will be automatically billed.
Please review the documents below if you have questions about our badge service.
Radiation Safety FAQs
|Do I need a radioactive materials license?|
If you operate Troxler nuclear gauges in the United States or Canada, the answer is “yes.” In other countries, check with your national authority for the regulation of radioactive materials. In the United States, the US Nuclear Regulatory Commission (NRC) regulates radioactive materials contained in nuclear gauges or by the radiation control program office in Agreement States. Guidance on licensing is contained in Troxler’s Licensing Guide.
|Do I need a copy of my gauge certificate?|
In addition to containing useful information about the radioactive material in your gauge, your gauge certificate is a record of receipt for your gauge (if you are the original owner). It also contains the initial leak test results at the time of shipment to you. You may be asked by your regulatory agency for documentation of both gauge receipt and initial leak test results. If you need a replacement copy of your gauge certificate, contact our Radiation Safety department at 1.877.TROXLER (outside the USA +1.919.549.8661) or send us an e-mail.
|What are IAEA certificates of competent authority?|
Troxler gauges contain sealed sources, which have been designed to meet the durability testing requirements of the International Energy Agency for certification as “special form” radioactive materials. Special form sources are tested to demonstrate that they are unlikely to release their radioactive contents even under extreme conditions. In order to transport gauges containing special form sources, the shipper is required to have, on file, current copies of the IAEA certificates of competent authority for each source. Please note that certificates of competent authority have expiration dates. Reference the Special Form Certificates page to download copies of these forms.
|Do I need to placard my vehicle to transport my gauge?|
No. Placarding is required for vehicles that transport Yellow III quantities of radioactive material. Troxler gauges contain only White I or Yellow II quantities of radioactive material.
|Do I need a CDL (Commercial Driver’s License) to transport Troxler gauges?|
No. A CDL would only be required for greater than Yellow II quantities of radioactive material.
|What are the rules regarding securing my gauge in the vehicle?|
The US DOT regulations state that the gauge must be “securely blocked and braced to prevent shifting under conditions normally incident to transportation”. In addition, the gauge cannot be transported in the passenger compartment of the vehicle.
|What kind of training do I need to operate my gauge?|
In the US, gauge operator training is usually required as a provision of your radioactive materials license. In addition, US DOT regulations require initial and recurrent HAZMAT training for all employees involved in the transportation of hazardous goods, including packaging, preparing shipping papers, inspecting and transporting. HAZMAT training must cover regulatory requirements, recognition and identification of hazardous materials, emergency response information, hazard self-protection measures and accident prevention methods and procedures. See 49 CFR 172 subpart H for further details.Troxler regularly conducts 1 day gauge operator training classes and 2 hour HAZMAT re-certification sessions at various locations around the country. Please visit the Training section of our web site for more details.
|How do I complete a bill of lading?|
The Troxler Transportation Guide gives examples of bills of lading for transportation to temporary job sites, as well as transportation by common carrier.
|What is a type A package?|
A type ‘A’ package conforms to the testing requirements of US DOT for the transportation of certain quantities of radioactive material. US DOT requires that you maintain Type ‘A’ testing results on file for two years past the date of your latest shipment. Documentation of Type ‘A’ testing is contained in the Troxler Transportation Guide.
|What is special form radioactive material?|
Special form radioactive sources have passed the testing criteria of the International Atomic Energy Agency (IAEA) for durability under extreme conditions. Troxler uses radioactive sources that are encapsulated in stainless steel and have been certified to IAEA standards. US DOT requires that you maintain a current copy of the IAEA certificate of competent authority for the design of special form radioactive material for each source in your gauge.
|How often do I have to leak test my gauge?|
Frequency of leak testing is specified in the conditions of your radioactive materials license. Most users are required to leak test their gauges every six months.
|What is the emergency response document?|
The emergency response document is required by US DOT to be attached to the shipping paper whenever you transport your gauge. It contains information for emergency responders about the characteristics of the hazardous material in case of an accident during transportation. Please reference the Troxler Transportation Guide for more information.
|What is the transport index?|
The transport index is the radiation dose rate expressed in millirem per hour at 1 meter from the surface of the package.
|Can I transfer my gauge to another company?|
US regulations state that prior to shipment to another user, you must verify that they are licensed to receive the type, form and quantity of radioactive material that you plan to transfer. This may be verified by obtaining and reviewing a copy of their radioactive materials license. Alternatively, you may obtain a letter from them stating that they are properly licensed to receive the type, form and quantity of radioactive material contained in the gauge you wish to transfer. Such a letter should include the name of the issuing agency, the license number and the expiration date of the license.
|Where do I get Special Form Certs (i.e. GB/140/S85, etc.)?|
Please reference the Special Form Certificates page of our web site.
|What are the usual radiation levels for my gauge?|
Please reference your gauge Operator’s Manual for the answer to this question.
|Do I need a MSDS for my nuclear gauges?|
No. Troxler provides a MSDS disclaimer statement for your files.
|What is reciprocity and how can I use my gauge in another state?|
The regulatory authority for portable nuclear gauges in many states is the US Nuclear Regulatory Agency. Other states which have entered into an agreement with the USNRC (and therefore are referred to as ‘agreement states’) have agencies which have regulatory authority for portable nuclear gauges in their state. So, how do you work in a state which is regulated by an agency other than your own?Most states have a system of “reciprocity” for portable nuclear gauge licenses. This means that if you send them a request and any applicable fees, they will issue you a “letter of reciprocity” authorizing you to use your gauge in their state for some period (usually less than 180 days per year) as long as you adhere to their rules and regulations. How does this all work?The requirements for reciprocity vary from agency to agency, so the first step is a call to the state regulatory agency where you wish to do work. They will direct you as to what they require for you to work in the state. A list of regulatory agencies and contact telephone numbers are available in the Troxler Transportation Guide.
|Please reference the Troxler Transportation Guide for the answers to the following questions:|
|How do I apply for a Radioactive Materials license?How do I fill out a Radioactive Materials license application?How do I calculate Dose to Members of the public?What is the element name and mass number for the sources?What is the chemical and physical form of the sources?What are the activities of the radioactive sources?What are the model numbers for the sources?What should my radiation protection program look like?Do I need to have a survey meter (radiation detection instrument)?How do I fill out shipping papers for my gauge?Where do I find Type A package testing results for my case?Where do I get an emergency response sheet?What emergency contact telephone number should I have?How do I transport my gauge in my vehicle?How do I label my shipping case?|