Volume XIII, Edition 9 September 1, 2013 GATEKEEPER NEWSLETTER Arizona Emergency Response Commission 5636 East McDowell Road Phoenix, Arizona 85008-3495 Wendy Smith-Reeve, Chair Janice K. Brewer, Governor http://www.governor.state.az.us/ http://www.dem.azdema.gov/ Mark Howard, Executive Director http://www.azserc.org EPA Revises Hazardous Waste Rules for Shop Towels: Inside this issue: Obama Signs Executive Order to Improve Federal, State, and Local Coordination for Chemical Emergencies: Chemical spill shuts middle school: $1.1 Million Fine for Fall Hazards: The Difference Between D001 Ignitable Compressed Gas and DOT 2.1 Flammable Gas [40 CFR 261.21 and 49 CFR 173.115 (a)]: Exceptions for Shipments of Solids Containing Flammable Liquids by Ground [49 CFR 172.102, Special Provision 47]: EPA is revising the hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA) to conditionally exclude solvent-contaminated wipes from 4 hazardous waste regulations provided that businesses clean or dispose of them properly. The rule is based on EPA’s final risk analysis, which was 6 peer reviewed in 2008 and published for public comment in 2009, that concluded wipes contaminated with certain hazardous solvents do not pose significant risk to human health 8 and the environment when managed properly. EPA estimates that the final rule will result in a net savings of between $21.7 million and $27.8 million per year. 2 10 Wipes are used in conjunction with solvents for cleaning and other purposes by tens of thousands of facilities in numerous industrial sectors, such as printers, automobile repair shops, and manufacturers of automobiles, electronics, furniture, and chemicals. “Today’s rule uses the latest science to provide a regulatory framework for managing solvent-contaminated wipes that is appropriate to the level of risk posed by these materials,” said Mathy Stanislaus, assistant ad- ministrator for EPA’s Office of Solid Waste and Emergency Response. “I’ve heard directly from stakeholders about the benefits of this rule and the need to finalize it. The rule reduces costs for thousands of businesses, many of which are small businesses, while maintaining protection of human health and the environment.” The new final rule excludes wipes that are contaminated with solvents listed as hazardous wastes under RCRA that are cleaned or disposed of properly. To be excluded, solventcontaminated wipes must be managed in closed, labeled containers and cannot contain free liquids when sent for cleaning or disposal. Additionally, facilities that generate solvent-contaminated wipes must comply with certain recordkeeping requirements and may not accumulate wipes for longer than 180 days. EPA estimates that the final rule will result in a net savings of $18 million per year in avoided regulatory costs and between $3.7 million and $9.9 million per year in other expected benefits, including pollution prevention, waste minimization and fire prevention benefits. The rule is consistent with President Obama’s Executive Order 13563, Improving Regulation and Regulatory Review, which charges federal agencies to monitor regulatory effectiveness and to help make agency regulatory programs more effective or less burdensome in achieving the regulatory objectives. EPA first proposed modified regulations for solventcontaminated wipes on November 20, 2003, and published a revised risk assessment for public comment on October 27, 2009. The docket for this rulemaking is EPA-HQ-RCRA-2003-0004 and can be accessed at http:// www.regulations.gov once the final rule is published. Learn more about the shop towel rule and how to comply with the latest hazardous waste regulations by attending Environmental Resource Center’s hazardous waste training. LEPC Corner Page 2 GATEKEEPER Obama Signs Executive Order to Improve Federal, State, and Local Coordination for Chemical Emergencies: President Obama signed the Executive Order on the heels of a string of large chemical accidents which have resulted in the deaths of First Responders and civilians, most notably the incident in West, Texas. Read the Executive Order. The main goals of the order are: -improving coordination with state and local partners on risk management and emergency planning for chemical emergencies, -enhancing information sharing among federal agencies, Department of Labor, that will provide a status update within 270 days of the order. -the modernization of various chemical security regulations, and stakeholder outreach to develop industry best practices. The TIER II MANAGER software provides a readymade solution built on a decade of experience from the Hazmat industry and first responders to address these very issues. It is a proven solution that can be implemented quickly to meet a comprehensive set of chemical risk intelligence and emer- -The order calls for the formation of a working group, co-chaired by the Environmental Protection Agency, Department of Homeland Security, and the gency planning needs. See how others use it. To read the entire Executive Order go to: http:// www.whitehouse.gov/thepress-office/2013/08/01/ executive-order-improvingchemical-facility-safetyand-security Oklahoma courthouse evacuated after chemical spill: Associated Press – (Oklahoma) Oklahoma courthouse evacuated after chemical spill. A chemical spill near the Sequoyah County courthouse in Sallisaw prompted the courthouse’s closure August 1 as the building was evacuated after a milky-white chemical started leaking from a truck parked near the courthouse. Officials deter- mined the chemical was a nonhazardous solvent. Source: http:// newsok.com/oklahoma-courthouseevacuated-after-chemical-spill/ article/3868415 Dozens of teen workers sprayed with fungicide: Associated Press – (Illinois) Dozens of teen workers sprayed with fungicide. About 70 teenagers were sent to an Illinois hospital for treatment and decontamination after they were accidentally sprayed with fungicide while working in a corn field near Pesotum July 25. The teenagers were detasseling corn when the chemical drifted over them from an airplane that was crop dusting an adjacent field. Source: http://news.msn.com/us/ dozens-of-teen-workers-sprayedwith-fungicide Volume XIII, Edition 9 Page 3 Federal Railroad Administration Issues Emergency Order to Prevent Unintended Hazardous Materials Train Movement: The Pipeline and Hazardous Materials Safety Administration and the Federal Railroad Administration Issue Joint Safety Advisory Regarding Rail Shipment of Hazardous Materials WASHINGTON – The U.S. Department of Transportation’s Federal Railroad Administration (FRA) today issued an Emergency Order and Safety Advisory to help prevent trains operating on mainline tracks or sidings from moving unintentionally. The FRA’s announcement was made in response to the July 6, 2013 derailment in Lac-Mégantic, Quebec, Canada, as it awaits additional data once the investigation into the crash is complete. The actions announced today build on the success of FRA’s rigorous safety program, which has helped reduce train accidents by 43 percent over the last decade, and made 2012 the safest year in American rail history. The Emergency Order is a mandatory directive to the rail industry, and failure to comply will result in enforcement actions against violating railroads. “Safety is our top priority,” said U.S. Transportation Secretary Anthony Foxx. “While we wait for the full investigation to conclude, the Department is taking steps today to help prevent a similar incident from occurring in the United States.” Today’s Emergency Order outlines measures that all railroads must undertake within the next 30 days: • No train or vehicles transporting specified hazardous materials can be left unattended on a mainline track or side track outside a yard or terminal, unless specifically authorized. • In order to receive authorization to leave a train unattended, railroads must develop and submit to FRA a process for securing unattended trains transporting hazardous materials, including locking the locomotive or otherwise disabling it, and reporting among employees to ensure the correct number of hand brakes are applied. • Employees who are responsible for securing trains and vehicles transporting such specified hazardous material must communicate with the train dispatchers the number of hand brakes applied, the tonnage and length of the train or vehicle, the grade and terrain features of the track, any relevant weather conditions, and the type of equipment being secured. • Train dispatchers must record the information provided. The dispatcher or other qualified railroad employee must verify that the securement meets the railroad’s requirements, and they must verify that the securement meets the railroad’s requirements. • Railroads must implement rules ensuring that any employee involved in securing a train participate in daily job briefings prior to the work being performed. • Railroads must develop procedures to ensure a qualified railroad employee inspects all equipment that an emergency responder has been on, under or between before the train can be left unattended. • Railroads must provide this EO to all affected employees. “Today’s action builds upon a comprehensive regulatory framework we have had in place for some time,” said FRA Administrator Joseph C. Szabo. “The safe shipment of all cargo is paramount and protecting the safety of the American public is fundamental to our enforcement strategy and we are encouraged by the industry’s willingness to cooperate with this approach going forward.” In addition to the Emergency Order, the FRA, together with the Pipelines and Hazardous Materials Safety Administration (PHMSA), issued a Safety Advisory detailing a list of recommendations railroads are expected to follow. U. S. DOT believes that railroad safety is enhanced through the use of multiple crew members, and the Safety Advisory recommends railroads review their crew staffing requirements for transporting hazardous material and ensure that they are adequate. Other recommendations in the Safety Advisory include: conducting system-wide evaluations to identify particular haz- ards that may make it more difficult to secure a train or pose other safety risks and to develop procedures to mitigate those risks. A copy of the Safety Advisory can be viewed HERE. “When PHMSA talks about the transportation of hazardous materials, safety is a prerequisite to movement,” said PHMSA Administrator Cynthia Quarterman. “We are taking this action today and we will be looking hard at the current rail operating practices for hazardous materials to ensure the public's safety.” As FRA continues to evaluate safety procedures following the recent crash, it will convene an emergency meeting of its Railroad Safety Advisory Committee to consider what additional safety measures may be required. FRA plans to develop a website that will allow the public to track industry compliance with the Emergency Order and Safety Advisory issued today. FRA has developed a plan that outlines six major actions that have occurred or will occur to further ensure that our regulatory response to the Canadian rail accident remains transparent. Under current DOT regulations, all freight railroads are required to develop and implement risk assessments and security plans in order to transport any hazardous material, including a plan to prevent unauthorized access in rail yards, facilities and trains carrying hazardous materials. Railroads that carry hazardous materials are required to develop and follow a security protocol while en route; railroad employees are subject to background checks and must complete training. Training programs and protocols are reviewed and audited by the FRA routinely and generally designed to be progressive so as the level of risk increases so does the level of security required. A description of past, present, and proposed FRA actions on this issue can be found here. GATEKEEPER Page 4 18 treated after Texas Roadhouse chemical accident: Blount Memorial Hospital officials said they started individually releasing patients early Saturday morning. Josh West, Public Relations Manager at Blount Memorial Hospital, said 18 people were treated after a chemical incident at the Texas Roadhouse in Alcoa. chemical incident at the Alcoa Texas Roadhouse. the air and remove the chemical smell. He says an employee accidentally improperly mixed chemicals including bleach, which created a chemical gas. Daffron says the restaurant should be able to reopen for business on Saturday. Update-- 10:25 p.m. (WBIR - Alcoa) Update-10:50 p.m. The patients mainly had skin, eye and lung irritation. Daffron says the people were all conscious when they were taken to the hospital. Blount Memorial hospital confirms they are treating five people after a hazardous materials incident at the Texas Roadhouse in Alcoa. Alcoa Deputy Fire Chief Tom Daffron says 17 people have been taken to the hospital after a He says crews are working inside the restaurant to ventilate the building, monitor Rural Metro also says they have sent four ambulances from Knox County to the res- taurant. Dispatchers tell 10News the building has been evacuated. They cannot confirm the nature of the situation. Previous story-- 10:05 p.m. Blount Co. dispatch confirms at least two people are receiving treatment after a hazmat situation at Texas Roadhouse in Alcoa. CAMEO Companion is now available for printing please contact: State of Arizona Department of Corrections Dirk Johnson, Account Manager 3107 W. Cambridge Avenue Phoenix, AZ 85009 602-272-7600 Ext. 207 Toll Free: 800-992-1738 Fax: 602-272-1007 Cell: 602-388-7230 djohnso1@azcorrections.gov Chemical spill shuts middle school: Firefighters from Niverville and Valatie responded to Ichabod Crane Middle School at 2910 Route 9 Monday morning due to a dangerous chemical reaction. Firefighters were called to the school at 6:47 a.m., and the roughly half-dozen district employees in the school were evacuated when toxic fumes began to fill the school’s hallways. “Toilet bowl cleaner got into another material which created a toxic cloud that set off the fire alarms,” said Niverville Fire Chief Wayne Huyck. There were no students in the building at the time of the incident and the OK Kids Day Care program was redirected to the nearby primary school, according to a statement released by the district. A custodian was examined by emergency responders but was released after examination. The Columbia County Hazardous Materials Team was called in to clean up the chemicals, and responders were back in service at 9:45 a.m., Huyck said. There were no injuries. Volume XIII, Edition 9 Industry Corner Page 5 How to Mark Fumigated Cargo Transport Units (UN3359) Shipped by Vessel [IMDG Code 5.5.2 and 5.5.2.3.2]: Cargo transport units (CTUs) shipped by vessel that have been fumigated (UN3359), but are not carrying dangerous goods, are subject to special provisions for marking in Chapter 5.5.2 of the International Maritime Dangerous Goods (IMDG) Code. Fumigated CTUs that contain dangerous goods are subject to both the requirements of 5.5.2, as well as the IMDG Code provisions relevant to those goods. To be transported as cargo under fumigation, fumigated CTUs must be closed in such a way that escape of gas is reduced to a minimum. Personnel who handle fumigated CTUs must be trained in his or her job responsibilities. Fumigated CTUs must be marked with the IMDG Code Chapter 5.5.2.3.2 warning mark (see below), with this mark affixed at each access point where it will be seen easily. The warning mark must remain on the fumigated CTU until the following conditions are met: The CTU has been ventilated to remove harmful concentrations of fumigant gas; and The fumigation goods or materials have been unloaded. The warning mark must be rectangular and a minimum of 300mm wide x 250mm high. The lettering on the mark must be at least 25mm high and must be in black print on a white background. ventilation must be written on the fumigation warning mark. When the fumigated CTU has been ventilated and unloaded, the mark must be removed. Class 9 placards must not be affixed to the fumigated CTU, except as required when other Class 9 substances or articles are contained in the CTU. Learn more about these and other IMDG Code regulations by attending Environmental Resource Center's International Maritime Dangerous Goods (IMDG) Code Webcast or the Transportation of Dangerous Goods: Compliance with IATA and IMO Regulations seminar. If the CTU has been completely ventilated by either mechanical ventilation or by opening the doors, the date of the TRANSCAER® (Transportation Community Awareness and Emergency Response) is a voluntary national outreach effort that focuses on assisting communities prepare for and respond to a possible hazardous material transportation incident. TRANSCAER® members consist of volunteer representatives from the chemical manufacturing, transportation, distributor, and emergency response industries, as well as the government. Visit: http://www.transcaer.com/state.aspx for more information. GATEKEEPER Page 6 $1.1 Million Fine for Fall Hazards: Republic Steel has been cited by OSHA for 24 safety violations carrying fines of $1,138,500. Fifteen willful violations of OSHA's fall protection standards were found at the company's Canton steel manufacturing plant. OSHA received a formal complaint from the United Steelworkers Union alleging inadequate fall protection and other unsafe practices exposing workers to various hazards in the plant's melt shop. During the inspection, opened in February 2013, OSHA discovered that two workers had been seriously injured in falls at the site in June and August of 2012. "People working hard to provide for their families should not have worry each day whether they'll come home," said Secretary of Labor Thomas E. Perez. "Republic Steel put their workers' lives in danger, and that kind of disregard for safety will not be tolerated." The company has a history of failing to address fall hazards. In 2011, after an employee was seriously injured in a fall at the company's Lorain, Ohio, facility, OSHA issued willful citations to the company for fall hazards. In a settlement entered into with OSHA in 2012, the company accepted three willful fall hazard violations at the Lorain plant and to address fall protection at its plants, includ- ing the Canton plant. "Republic Steel has a long history of OSHA violations and disregard for employee safety and health," said Dr. David Michaels, assistant secretary of labor for occupational safety and health. "It is unacceptable that Republic Steel has not taken more effective steps to improve safety at the Canton plant, particularly in light of a 2012 settlement aimed at exactly that. OSHA will remain diligent in its commitment to protect America's steel workers." A total of 15 willful violations were cited for failing to provide fall protection in the Canton steel mill. Among the violations noted were lack of fall protection while working on the runway girders that were 66 feet above the ground and falls of 30 feet due to missing and damaged guardrails. Workers were also exposed to falls of up to 30 feet above the slag pit and falls of 20 feet above the electric arc furnace and molten steel ladle. A willful violation is one committed with intentional, knowing or voluntary disregard for the law's requirements, or plain indifference to employee safety and health. One repeat violation was cited for failing to post danger signs or other effective means of indicating the existence and location of permitrequired confined spaces in the melt shop. OSHA issues repeat violations if an employer previously was cited for the same or a similar violation of any standard, regulation, rule or order at any other facility in federal enforcement states within the last five years. The same violation was cited in August 2009 at the company's facility in Blasdell, New York. Additionally, eight serious violations include tripping hazards, the use of electrical panels not suitable for wet locations, lack of personal protective equipment for employees working around the furnace, failing to evaluate potential hazards in confined spaces that employees might need to enter such as furnaces and duct work, and failure to train workers on hazards and issue entry permits for those spaces. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known. Republic Steel will remain in OSHA's Severe Violator Enforcement Program, which mandates targeted follow-up inspections to ensure compli- ance with the law. The company was placed in the program in 2011. OSHA's severe violator program focuses on recalcitrant employers that endanger workers by committing willful, repeat or failure-toabate violations. Under the program, OSHA may inspect any of the employer's facilities if it has reasonable grounds to believe there are similar violations. The company, which is headquartered in Canton, employs approximately 2,500 workers companywide and 600 at the Canton mill. Other Republic Steel mills are located in Massillon and Lorain, Ohio, and Blasdell, New York. The Canton plant has been inspected by OSHA 16 times, which resulted in one willful, two repeat, 22 serious and 23 other-thanserious final order citations. As a corporate entity, Republic Steel has been inspected 79 times resulting in the issuance of six willful, 15 repeat, 145 serious and 70 other-thanserious final order citations. Volume XIII, Edition 9 Page 7 Are You a Used Oil Generator?: A used oil generator is any person, by site, who produces used oil or causes used oil to become subject to regulation. Generators include all persons who produce used oil through commercial or industrial operations and vehicle services. Storage Requirements The rules state that generators must not store used oil in units other than tanks, containers, or units regulated under 40 CFR 264 or 40 CFR 265 (40 CFR 279.22(a)). (Tanks include both aboveground storage tanks (ASTs) and underground storage tanks (USTs)). According to EPA, this does not mean that the ASTs or containers must meet the respective container and tank requirements of 40 CFR 264 or 40 CFR 265, just that storage in those regulated containers and tanks is allowed. However, used oil cannot be stored in another type of unit (e.g., a surface impoundment) unless it is a permitted hazardous waste unit. The determination as to which storage units must be used for mixtures of used oil and hazardous waste is based on whether the used oil mixture is to be managed as a used oil or as a hazardous waste. Under the used oil storage rules for generators, the options are as follows: • Used oil or used oil mixtures managed as used oil can be stored in tanks or containers that either are or are not regulated under 40 CFR 264 or 40 CFR 265. • Used oil mixtures managed as hazardous waste must be stored in tanks or containers that comply with 40 CFR 264 or 40 CFR 265. • Units other than tanks or containers that store used oil or any used oil mixture must be permitted under 40 CFR 270 and the units must meet specific standards of 40 CFR 264 or 40 CFR 265. Generators must ensure that all containers and ASTs are free of any visible spills or leaks as well as structural damage or deterioration. All ASTs or containers that are used must be in good condition and be properly labeled as "used oil." Fill pipes that transfer used oil into USTs must be marked clearly with the words "used oil." If used oil is stored in a UST, that UST would have to comply with the standards for USTs, including those at 40 CFR 280. Release Response Upon discovering an oil release from an AST or container, the following procedures should be followed: • Stop the release. • Contain the released used oil. • Clean up and manage properly the released used oil and other materials. • If necessary to prevent future releases, repair or replace any leaking used oil storage containers or tanks before returning them to service. This requirement applies only when there is a release to the environment. This does not include releases within contained areas such as concrete floors or impervious containment areas, unless the releases go beyond the contained areas. It does not apply to releases from USTs subject to the release response and corrective action regulations of 40 CFR 280. Generators that store used oil in ASTs or in certain USTs must develop and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan (40 CFR 112) and comply with the applicable AST and UST requirements concerning releases. Off-Site Shipments Generators must use a transporter that has an EPA ID number, except: • When transporting oil that the generator has generated to a collection center or aggregation point for recycling, provided that: —The used oil is transported in a vehicle owned by either the generator or by an employee of the generator. —The generator ships no more than 55 gallons of used oil at any one time. —The used oil collection center is registered, licensed, permitted, or recognized by the state, county, or municipality to manage used oil. —The aggregation point is owned or operated by the generator. When the used oil is being reclaimed under a contractual agreement (known as a "tolling agreement") under which reclaimed oil is returned by the processor/ rerefiner to the generator for use as a lubricant, cutting oil, or coolant, provided that the tolling agreement indicates: —The type of used oil and the frequency of shipments, — That the vehicle used to transport the used oil to and from the processor/ rerefiner is owned and operated by the processor/ rerefiner, and —That reclaimed oil will be returned to the generator. Burning in Space Heaters Generators may burn used oil in used oil-fired space heaters provided that: • The heater burns only used oil that the owner or operator generates or used oil received from household do-it-yourself (DIY) used oil generators. • The heater is designed to have a maximum capacity of not more than 0.5 million British thermal units per hour. The combustion gases from the heater are vented to the ambient air. GATEKEEPER Page 8 The Difference Between D001 Ignitable Compressed Gas and DOT 2.1 Flammable Gas [40 CFR 261.21 and 49 CFR 173.115(a)]: EPA and DOT use somewhat similar terms when classifying materials that they regulate. However, the terms are defined differently. In this Reg of the DayTM, we will look into the differences between ignitable gases, as defined by EPA, and flammable gases, as defined by DOT. When you determine if a gas is classified as a hazardous waste, you must determine if it is ignitable (EPA waste code D001), and when you ship gases off-site, you must determine if they are flammable (DOT Division 2.1). To determine if a gas is D001, it must be both a compressed gas and be ignitable as defined at 40 CFR 261.21. compressed gas is any material or mixture having in a container an absolute pressure exceeding 40 psi at 70 °F or, regardless of the pressure at 70 °F has an absolute pressure exceeding 104 psi at 130 °F; or is any liquid flammable material having a vapor pressure exceeding 40 psi absolute (psia) at 100 °F as determined by ASTM Test D-323. A compressed gas is ignitable if any of the following occurs: At atmospheric pressure (14.7 psia), either a mixture of 13% or less (by volume) with air forms a flammable mixture, or the flammable range with air is wider than 12% regardless of the lower limit Using the Bureau of Explosives’ Flame Projection Apparatus, the flame projects more than 18 inches beyond the ignition source with valve opened fully, or the flame flashes back and burns at the valve with any degree of valve opening Using the Bureau of Explosives’ Open Drum Apparatus, there is any significant propagation of flame away from the ignition source Using the Bureau of Explosives’ Closed Drum Apparatus, there is any explosion of the vapor-air mixture in the drum flammable gas [49 CFR 173.115(a)] is a material that is a gas at 68 °F or less at atmospheric pressure (14.7 psia), or has a boiling point of 68 °F or less at 14.7 psia, and any of the following: Is ignitable at 14.7 psia in a mixture with air at 13% or less by volume Has a flammable range at 14.7 psia with air of at least 12% regardless of the lower limit For aerosols, if the contents include 85% by mass or more flammable components and the chemical heat of combustion is 30 kJ/g, or is classed as flammable per the appropriate tests of the UN Manual of Tests and Criteria Learn more about how to ship hazardous materials by attending Environmental Resource Center’s DOT Hazardous Materials Training: The Complete Course seminar, DOT Hazardous Materials Training: The Complete Course webcast, or DOT Hazardous Materials Update webcast. According to the DOT hazardous materials regulations, a Division 2.1 The differences in these definitions are summarized in the following table. Property or Test Gas criteria EPA D001 Compressed gas: 40 psi @ 70°F or 104 psi @ 130 °F DOT 2.1 Gas at < 68 °F or boiling point of < 68 °F at ambient pressure Flammable liquid with high Flammable liquid with vapor No equivalent vapor pressure at 100 °F pressure > 40 psi @ 100 °F Flammable range in air Mixture of 13% or less with Same air forms a flammable mixture or the flammable range with air is wider than 12% regardless of the lower limit Aerosols US Bureau of Explosives Similar test per UN method flame projection test Volume XIII, Edition 9 Page 9 How to Ship Instruments or Articles Containing Class 7 Radioactives as Excepted Packages by Ground [49 CFR 173.435, 173.410, 173.422, and 173.424]: If an instrument or article contains a Class 7 radioactive material in a gaseous or nondispersible solid form as a component part, it is subject to the DOT’s hazardous materials regulations when offered for transportation. −1 2.0 5.4×10 2.0 EleSym- ment bol of and raatomic dionuc numA1 lide ber (TBq) Ac-227 (a) Ag105 Ag108m (a) Ag110m (a) Ag111 8.0×10 −1 9.0×10 −1 Ac-228 6.0×10 Silver (47) mal conditions of transport (e.g., acceleration, vibration) • Compatible with contents Valves protected from unauthorized operation Excepted instruments or articles must meet the requirements of 49 CFR 173.424 which include: • Activity within relevant Excepted packages must be limits per article or instrudesigned to meet the rement and per package quirements of 49 CFR • Radiation level of no 173.410 which include: more than 10 mrem/hour at • Surface does not allow 4 inches from package surwater to collect in pockets face if unpackaged or crevices • Features do not reduce • Active material enclosed by non-active compackage safety ponents • Able to withstand nor• Radiation level of no more than 0.5 mrem/ hour at any point on Specific activity the surface of package, or 2 mrem/hour for exclusive use, A1(Ci) A2 A2(Ci) (TBq/ domestic transport b b (TBq) g) (Ci/g) • Active material 2.2×10 6.0×10 1.6×10 2.1×10 5.8×10 enclosed by non1 −3 −1 3 4 active components • Non-fixed 2.4×10 9.0×10 2.4×10 2.7 7.2×10 (removable) surface 1 −5 −3 1 contamination within required limits No more than 15 g of 1.6×10 5.0×10 1.4×10 8.4×10 2.2×10 uranium-235 except 1 −1 1 4 6 To determine if a Class 7 radioactive instrument or article ground shipment qualifies as an excepted shipment, the radioactivity emission must be measured to determine the types of required packages and if exceptions are permitted for your shipment. To make this determination, look up the specific radionuclide you plan to ship in the table of A1 and A2 values at 49 CFR 173.435 (see table excerpt below). The table indicates exception values for A1 Ac-225 Actin(a) ium (89) (special form materials) and A2 (normal form materials) allowed for shipment using a Type A package. If the measured radioactivity emission does not exceed the A1 or A2 values, a shipment by ground qualifies as an excepted package and must meet the applicable requirements identified below. 1 5.4×10 1.1×10 3.0×10 1 3 4 7.0×10 1.9×10 7.0×10 1.9×10 9.7×10 2.6×10 −1 1 −1 1 −1 1 4.0×10 1.1×10 4.0×10 1.1×10 1.8×10 4.7×10 −1 1 2.0 5.4×10 6.0×10 1.6×10 5.8×10 1.6×10 1 −1 −1 1 1 2 3 3 5 as provided for natural or depleted uranium at 49 CFR 173.426 All excepted packages containing Class 7 radioactive materials must meet the requirements of 49 CFR 173.422 which include: • Mark outside of package with UN number • Follow incident reporting requirements • Train hazmat employees Provide shipping papers if excepted package contains a hazardous substance or hazardous waste Learn more about DOT’s hazardous materials regulations at Environmental Resource Center’s DOT Hazardous Materials training seminar or DOT Hazardous Materials training webcast. Meet your DOT refresher training requirements by attending Environmental Resource Center’s DOT Hazardous Materials Update webcast or DOT and RCRA Annual Update and Refresher seminar. GATEKEEPER Page 10 Exceptions for Shipments of Solids Containing Flammable Liquids by Ground [49 CFR 172.102, Special Provision 47]: DOT’s special provision 47 provides exceptions for shipments that qualify for the proper shipping name, Solids containing flammable liquids, n.o.s., from DOT’s hazardous materials regulations. This proper shipping name is used for materials such as contaminated soil, alcohol swabs, and sanitizing wipes. When you look up this proper shipping name in DOT’s hazardous materials table (49 CFR 172.101), column 7 lists the number 47 as a special provision for these materials. Special provision 47—listed at 49 CFR 172.102—identifies the criteria a shipment must meet to qualify for this exception: Each small inner packaging consists of sealed packets of 10 mL or less, Flammable liquids are fully absorbed onto a solid surface, and No free liquid is visible at the time the material is loaded. excepted from all DOT hazardous material requirements for ground transportation, including training, packaging, marks, labels, placarding, and shipping papers. Learn more about exceptions available for your hazardous materials by attending Environmental Resource Center’s DOT Hazardous Materials Training: The Complete Course or webcast. Shipments that meet these criteria are Governor's Tribal Community Outreach: Visit: http://azgovernor.gov/eop/TribalOutreach.asp for agency contact information. Tribal Program Link: http://www.epa.gov/region09/indian Tribal news: http://www.navajohopiobserver.com/ Tribal Program Newsletter: http://www.epa.gov/region09/indian/newslet.html LET’S HEAR FROM YOU! Send us your inputs and feedback on the newsletter; including, exercises and other LEPC related activities in which you've been involved. Let us know what you’d like to see in future editions. Talk to us! We appreciate your input and look forward to hearing from you! Sincerely, Mark Howard Executive Director Commercial products and services are mentioned for informational purposes only and should not be construed as AZSERC endorsements. COMMISSIONERS: ARIZONA EMERGENCY RESPONSE COMMISSION 5636 E. MCDOWELL ROAD PHOENIX, AZ 85008-3495 PHONE: (602) 464-6346 FAX: (602) 464-6519 Visit us on the web:www.azserc.org AZSERC STAFF Mark Howard Executive Director Roger Soden HAZMAT Program Coordinator Paul Culberson Sylvia Castillo Will Humble ADHS Acting Director Henry Darwin ADEQ Director John Halikowski ADOT Director Robert Halliday ADPS Director DESIGNEES: Mark Howard ADEM Don Herrington ADHS Veronica Garcia ADEQ David Denlinger ADPS Sonya Herrera ADOT ADVISORY COMMITTEE: Corporation Commission - Tom Whitmer Industrial Commission - Darin Perkins Admin Asst III State Mine Inspector - Joe Hart State Fire Marshal - Bob Barger Radiation Regulatory Agency - Aubrey Godwin Department of Agriculture - Jack Peterson our Organization The AZSERC was established by Arizona Law (Arizona Revised Statutes-Title 26, Chapter 2, Article 3) and is tasked with the implementation of the Emergency Planning and Community Right to Know Act (EPRCA) in Arizona. This Commission oversees 15 Local Emergency Planning Committees and supports community, industry and government and academia in: planning, release and incident reporting, data management guidance for inventory reporting, public disclosure of information about hazardous chemicals in Arizona as well as development of training and outreach programs. The Commission supports individual agency goals and objectives. ADEM Director (Chair) Web Portal/ Technology Coordinator Chrissy McCullough Admin Asst III About Wendy Smith-Reeve This is accomplished through the receipt and coordination of emergency notifications of chemical releases, collection and provision of chemical inventory information to interested parties, training and grants programs. Additionally, the AZSERC provides consultative services, conducts and participates in workshops and coordinates development and review of plans and programs for 15 Local Emergency Planning Committees. Further, the AZSERC serves as a state clearinghouse for hazardous chemical emergency preparedness and planning activities and information through coordination with federal, tribal, state, local governments, industry and community interest Arizona Fire Chiefs Association -Mesa FD - Dan Stubbs -Yuma FD - Jack McArthur Asst. State Attorney General - Jeffrey Cantrell SRP - Jeffrey Edmister Intel Corporation - Randy Holmes APS - Monica Ray Hamilton Sundstrand - David McWilliams GATEKEEPER NEWSLETTER: MARK HOWARD – EDITOR IN CHIEF CHRISSY MCCULLOUGH - EDITOR