Information Notice 1990-35, Transportation of Type a Quantities of Non-Fissile Radioactive Materials
| ML031210513 | |
| Person / Time | |
|---|---|
| Issue date: | 05/24/1990 |
| From: | Teneyck E Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| IN-90-035, NUDOCS 9005170283 | |
| Download: ML031210513 (10) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 May 24, 1990
NRC INFORMATION NOTICE NO. 90-35: TRANSPORTATION OF TYPE A QUANTITIES OF
NON-FISSILE RADIOACTIVE MATERIALS
Addressees
- All U.S. Nuclear Regulatory Commission (NRC) Licensees.
Purpose
This notice is provided to summarize and clarify the basic requirements of the
U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR)
that are most frequently cited as deficiencies or violations during inspections
of transportation activities of NRC licensees. Such deficiencies are most com- monly noted during inspections of byproduct materials licensees, particularly
when such licensees are first-time users of the regulations or those who package
and deliver such packages to carriers only occasionally. However, the infor- mation here should be useful to any type of licensee who prepares and delivers
radioactive material packages to carriers or transports packages in his own
vehicle as a private carrier.
It is expected that addressees will review the information here for appli- cability to their licensed activities and consider actions, as appropriate, to avoid problems in transport of such materials. However, suggestions
contained in this notice do not constitute any new requirements, and no
written response is required.
Background:
In 1979, NRC incorporated into its own regulations (10 CFR Part 71) the DOT
regulations contained in 49 CFR Parts 170 to 178. (See 10 CFR 71.5.)
This notice is an update of NRC IE Information Notice No. 82-47 (Ref. 1),
bearing the same title, issued November 30, 1982, and a series of three
articles which appeared in NRC NMSS Licensee Newletter, during 1989.
(Refs. 2, 3, 4.)
Discussion:
Special Form vs. Normal Form Determination
For transportation purposes, radioactive materials are classified either as
'special form" or "normal form," as defined in 49 CFR 173.403(s) and (z).
Radioactive materials classified as "special form," such as sealed sources,
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IN 90-35 May 24, 1990 may be transported with fewer restrictions than other materials with equal
radioactivity. However, sealed sources must meet the physical integrity
requirements defined in 49 CFR 173.469. All other radioactive materials
are considered 'normal form." For a particular shipping package specification, the activity limits for special form material usually are greater than those
for normal form materials (49 CFR 173.435). That is, if the material is in
special form, a greater quantity of material usually is permitted in the
package.
Any licensee who ships or transports special form material, and declares it
as such on shipping papers and package marking, must maintain documentation
containing the results of the testing performed on the material or source, to demonstrate that it meets the special form requirements [49 CFR 173.476(a)].
This does not mean that each shipper or transporter must perform the tests, but that each must obtain and retain the test documentation. Each licensee
should establish a file of such data for each special form design in its
possession. It is usually necessary for the licensee to obtain this infor- mation from the source or device manufacturer.
Type A vs. Type B Package Determination
Normal form materials in quantities no greater than applicable A limits
(curies), specified in 49 CFR 173.435, may be shipped in a packaie called
a "Type Am package (i.e., one which is expected to maintain its integrity
only during normal conditions of transport). Similarly, special form
materials may be shipped in larger quantities up to the A limit, in a
Type A package. Shipment of materials in a single package in excess of
these limits requires the use of the higher quality "Type B" package.
(i.e., one which is expected to maintain its integrity during both normal
and severe accident conditions of transport).
Examples of AI and A2 limits (in curies) from 49 CFR 173.435 are as follows:
Radionuclide A,(special form) A,(normal form)
Am-141 20 0.008 (in AmBe sources)
Ir-192 20 10
Mo-99 100 20
IN 90-35 May 24, 1990 In some instances, qualification of the material as *special form" will have
no bearing on the type of packaging required, relative to the activity of the
material shipped. For example, in the case of shipment of less than seven
curies of Co-60, Type A (rather than Type B) packaging may be used regardless
of form (normal or special), because the Type A package limit prescribed in
49 CFR 173.435 is seven curies for both special form (the A limit) and
normal form (the A limit). This contrasts with CS-137, where any quantity
exceeding 10 curiei (the A limit) in normal form requires Type B packaging, and as much as 30 curies ({he Al limit in special form) are allowed in Type A
packaging.
In any situation where the material is described on shipping papers and
package marking as "Radioactive material, special form, n.o.s." (n.o.s.
means *not otherwise specified"), the shipper is required to maintain the
special form documentation prescribed by 49 CFR 173.476(a). To avoid this
requirement, the shipper may elect to describe the material as "Radioactive
material, n.o.s.w However, this description may only be used if the special
form material in the Type A package does not exceed the normal form limit
(the A2 limit).
DOT Specification 7A, Type A Packages
As indicated previously, normal form materials can be shipped in a "Type A"
package, as long as the contained quantity does not exceed the A limits
(in curies) specified in 49 CFR 173.435. Similarly, special forW materials
that do not exceed the A1 limits (which, for certain materials, may be higher
than the A2 limits) also may be shipped in a Type A package.
The usual Type A package specification is referred to as "DOT Specification
7A" in 49 CFR 173.415(a). This is a pure "performance" specification and
is not based on any specific and detailed design specifications. For Speci- fication 7A, DOT regulations require that each shipper of a Specification 7A
package must maintain on file written documentation attesting to the results
of the Specification 7A performance tests performed on the package design.
Remember that a "shipper" also includes any NRC licensee transporting licensed
material in his own vehicle, (i.e., a "shipper" acting as a "private carrier").
If the shipper of a Specification 7A package is not the original designer
or user of that package, it is necessary for that shipper to obtain the
test result data from the original supplier. Alternately, the shipper
may perform the tests and document the results. The tests are described
in 49 CFR 173.465-466. Type A packages also must meet the design require- ments described in 49 CFR 173.411-412.
IN 90-35 May 24, 1990 If a shipper makes any changes, to the packaging or its maximum authorized
contents, from those described on the original test report furnished by
another person, the shipper must perform and document a supplemental
evaluation, addressing such changes, demonstrating that the package
will continue to meet the appropriate performance requirements.
(Reference 5, a U.S. Department of Energy (DOE) evaluation document for
Type A packaging, is a useful document which may be of value to shippers
in the preparation of their DOT Specification 7A documentations.)
Labeling (Labels are for packages.)
Each package must be labeled with one of the three "RADIOACTIVE" labels described
in 49 CFR 172.403. The three labels are referred to as RADIOACTIVE WHITE-I,
RADIOACTIVE YELLOW-Il, and RADIOACTIVE YELLOW-III. RADIOACTIVE WHITE-I is the
lowest category label and RADIOACTIVE YELLOW-III is the highest. Labels must
be affixed on each of two opposite sides of the package (49 CFR 172.406) and
must measure 4 inches on each side (49 CFR 172.407). DOT regulations display
the formats of these labels in 49 CFR 172.436-440.
All the labels include spaces for marking (1) the contents (the name of the
radionuclide) and (2) the activity (in curies, millicuries, or microcuries).
The YELLOW labels also include spaces for marking the Transport Index (TI).
The TI is a number expressing the maximum radiation level in millirem per
hour at 1 meter (3.3 feet) from the external surface of the package.
The appropriate label is selected based on the measured radiation levels
anywhere on the external surface of the package and based on the package
TI. A WHITE-I label may be used if the radiation level at any point on
the surface of the package does not exceed 0.5 mrem/hr. A YELLOW-II label
indicates that the surface rate does not exceed 50 mrem/hr and the TI does
not exceed 1. Higher radiation levels require use of the YELLOW-III label.
Pursuant to 49 CFR 173.441, package radiation levels are limited to 200
mrem/hr at the surface and 10 mrem/hr at 1 meter (i.e., a TI of 10).
Placarding (Placards are for vehicles.)
The outside of the transport vehicle must be placarded by the carrier on the
front, rear, and each side with the RADIOACTIVE placard (identified in 49 CFR
172.556) only if any package in the vehicle bears the RADIOACTIVE YELLOW-III
label. The licensee (shipper) is required to furnish the placards to a common
or contract carrier at the time the packages are delivered to, (i.e., picked
up by) that carrier. In the case of a licensee acting as a shipper/private
carrier, obviously, the licensee must apply the placards. Vehicles are not
required to be placarded when the shipment includes only WHITE-I or YELLOW-II
packages. [Note: In the case of exclusive-use shipments of low specific
activity (LSA) materials, the shipper must placard the vehicle, even though
such LSA packages are exceptedfr-o-mlabeling.]
IN 90-35 May 24, 1990 DOT placard requirements should not be confused with the posting requirements
of 10 CFR 20.203. Any temporary storage on a loading dock or transport vehicle
at a licensee's facility must also comply with the applicable requirements of
10 CFR Part 20, as well as with other appropriate NRC regulations.
Labels and placards should be procured commercially. They are not obtainable
from NRC.
Package Marking
The outside of each package must be marked with the following:
1. Applicable DOT Proper Shipping Name (see 49 CFR 172.101 List of Hazardous
Materials); and "RQ,w if a *reportable quantity" is present (see 49 CFR
172.101, Appendix Table 2, for radionuclide reportable quantities);
2. Identification Number (49 CFR 172.101);
3. Applicable DOT Specification, (e.g., "DOT-7A," "Type A");
4. Gross Weight [for packages in excess of 110 lbs (50 kilograms)];
5. The Marking "USA," if the package is destined for export;
6. The name and address of the consignee or consignor. (Both are recommended.)
Shipping Papers
A shipping paper is required for each transport of radioactive material from
the confines of the licensee's facility, whether transported by the licensee
in his own vehicles or delivered to a common carrier for transport. A properly
certified shipping paper is an indicator of compliance with DOT regulations and
is of prime importance to authorities in case of an accident, loss, or theft.
It must include the information required by 49 CFR 172.202-203, including the
following:
1. The applicable DOT proper shipping name from 49 CFR 172.101. (For
sources that are shipped as special form, this will always be uRadio- active material, special form, n.o.s." For normal form materials, the shipping name will generally be "Radioactive material, n.o.s.")
2. The applicable Identification Number from 49 CFR 172.101. (For materials
shipped as "Radioactive material special form, n.o.s.," this number is
UN2974. For materials shipped as "Radioactive material, n.o.s.," this
number is UN2982.)
3. For a radionuclide as a "hazardous substance' in a quantity exceeding the
applicable "reportable quantity," the entry "RQ" shall immediately precede
or follow the entries in 1 and 2, above.
- -
IN 90-35 May 24, 1990 4. The name of each radionuclide. (For example, "Co-60.")
5. A description of the physical and chemical form of the material. (For
special form sources, this description is "SPECIAL FORM.")
6. The activity contained in each package, measured in curie units.
7. The category of label applied to each package ("RADIOACTIVE WHITE-I,"
"RADIOACTIVE YELLOW-II," OR "RADIOACTIVE YELLOW-III").
8. The transport index (radiation level at 1 meter) assigned to each
package bearing YELLOW-II or YELLOW-IlI labels. (For packages
destined for carriage on passenger-carrying aircraft, the maximum
TI is 3 rather than 10.)
9. For shipments tendered to a common carrier, the appropriate signed
shipper's certification (49 CFR 172.204). For shipments by aircraft, the additional statement as to acceptability for either passenger- carrying or cargo-only aircraft. For shipments by passenger-carrying
aircraft, the additional statement of intended use in research, medical
diagnosis, or treatment must also be included.
10. An emergency response telephone number, for use in the event of an
emergency involving the package.
When licensees transport sealed source packages in their own vehicles repetitively, a reusable type of shipping paper documentation may be used that is specific
to each particular package configuration. Such documentation can take the
form of laminated cards retained in the cab of the vehicle, thereby eliminating
the need for preparing a new shipping paper document every time a shipment is
made.
Shipping papers must be maintained in the vehicle, within the immediate reach
of the driver restrained by the lap belt. Ordinarily, a glove compartment
does not meet this requirement. [49 CFR 177.817(e) provides detailed infor- mation on accessibility of shipping papers within vehicles.]
Blocking, Bracing, and Securing of Packages
Licensees who transport packages in their own vehicles must provide for
adequate blocking, bracing, or tie-down of the packages to prevent shifting
or movement during normal transport. Licensees also are required to provide
security measures adequate to prevent the unauthorized removal of materials
from the place of storage during transport, pursuant to 10 CFR 20.207. This
may involve locking the packages within an external, permanently-attached
compartment of the vehicle, or within the cargo compartment, itself. In
either case, it is necessary to remove the keys from the vehicle. (See
Reference 6, Information Notice No. 87-31, for further information on
blocking, bracing and securing of packages during transport.)
IN 90-35 May 24, 1990 A Caution - Obtain a Copy of the Regulations I
This notice is for information and guidance. Reference 7, a review of DOT
regulations on radioactive material transport, may also be useful to readers
of this notice. Neither source should be considered as a substitute for the
actual copy of the regulations. All licensees who package or transport radio- active packages are urged to avail themselves of up-to-date copies of the ap- plicable NRC and DOT regulations. Copies of these regulations (i.e., Title 49 of the Code of Federal Regulations) can be obtained from Superintendent of
Documents, U.S. Government Printing Office, Washington, D.C. 20402-9371
(202) 783-3238.
Future Regulatory Revision
This notice is based on the DOT and NRC regulations in effect at the time of
issuance of this notice. Readers are advised that both NRC and DOT are cur- rently in the midst of rulemaking actions to effect revisions to the regulations
of the U.S. so as to incorporate the latest standards of the International
Atomic Energy Agency in the 1985 edition (as supplemented) of its Safety
Series No. 6, "Regulations for the Safe Transport of Radioactive Materials."
(Ref. 8) The Notices of Proposed Rulemaking by each agency are listed in
References 9 and 10. It is estimated that final action on the regulatory
requirements will be taken in late 1990 or early 1991.
Eli eth Q. n Eyck, Acing Director
Di sion of Safeguards
and Transportation
Office of Nuclear Material Safety
and Safeguards
Technical Contacts: A. W. Grella, NMSS
(301) 492-3381 C. L. Cain, USNRC, Region IV
(817) 860-8186 Attachments:
1. References
2. List of Recently Issued NMSS Information Notices
3. List of Recently Issued NRC Information Notices
Attachment 1 IN 90-35 May 24, 1990 REFERENCES
1. U.S. Nuclear Regulatory Commission, IE Information Notice No. 82-47,
"Transportation of Type A Quantities of Non-Fissile Radioactive
Materials."
2. U.S. Nuclear Regulatory Commission, NMSS Licensee Newsletter, Office
of Nuclear Materials Safety and Safeguards, NUREG/BR-0117, No. 89-1, March 1989.
3. Ibid, No. 89-2, June 1989.
4. Ibid, No. 89-3, September 1989.
5. D. A. Edling et al., *DOE Evaluation Document for DOT 7A Type A Packaging,"
MLM-3245 (DOE7DV70O53-H1), March 1987.
6. NRC Information Notice No. 87-31, "Blocking, Bracing, and Securing of
Radioactive Materials Packages In Transportation," July 10, 1987.
7. U.S. Department of Transportation, "A Review of the Department of
Transportation Regulations for Transportation of Radioactive Materials,"
revised 1983. Available from U.S. Department of Transportation, Research and Special Programs Administration, Washington, DC (202-366-2301)
or U.S. Government Printing Office.
8. International Atomic Energy Agency, "Regulations for the Safe Transport
of Radioactive Material, Safety Series No. 6, 1985 Edition," as sup- plemented. Available in the U.S. from: BERNAN-UNIPUB, 4611-F Assembly
Drive, Lanham, Maryland 20706-4341.
9. U.S. Nuclear Regulatory Commission, "Transportation Regulations:
Compatibility with the International Atomic Energy Agency,"
Federal Register, Vol. 53, No. 110, June 8, 1988. (Proposed
Rule, 10 CF Part 71.)
10. U.S. Department of Transportation, Research and Special Programs
Administration, "Transportation Regulations: Compatibility with
Regulations of the International Atomic Energy Agency: Notice of
Proposed Rule," (49 CFR Part 171, et al.), Federal Register, Vol. 54, No. 218 (Part II), November 14, 1989.
Attachment 2 IN 90-35 May 24, 1990 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to:
90-27 Clarification of the 04/30/90 All Uranium Fuel
Recent Revisions to the Fabrication and Conversion
Regulatory Requirements Facilities
for Packaging of Uranium
Hexafluoride (UF6) for
Transportation
90-24 Transportation of Model 04/10/90 All NRC licensees
SPEC 2-T Radiographic authorized to use, Exposure Device transport, or operate
radiographic exposure
devices and source
changers
90-20 Personnel Injuries 03/22/90 All U.S. NRC licensees
Resulting from Improper who process or incinerate
Operation of Radwaste radioactive waste
Incinerators
90-16 Compliance with New 03/07/90 All materials licensees
Decommissioning Rule
90-15 Reciprocity: Notification 03/07/90 All holders of NRC
of Agreement State Radiation materials licenses that
Control Directors before authorize use of radio- Beginning Work in Agreement active material at
States temporary job sites
90-14 Accidental Disposal of 03/06/90 All NRC byproduct
Radioactive Materials materials licensees
90-09 Extended Interim Storage of 02/05/90 All holders of NRC
Low-Level Radioactive Waste materials licenses
by Fuel Cycle and Materials
Licensees
Correct Number for IN 90-01 should be 9001080145.
Attachment 3 IN 90-35 May 24, 1990 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
90-34 Response to False Siren 5/10/90 All holders of OLs
Activations or CPs for nuclear
power reactors.
90-33 Sources of Unexpected 5/9/90 All holders of OLs
Occupational Radiation or CPs for nuclear
Exposures at Spent Fuel power reactors.
Pools
90-32 Surface Crack and Subsurface 5/3/90 All holders of OLs
Indications in the Weld of or CPs for nuclear
A Reactor Vessel Head power reactors.
90-31 Update on Waste Form and 5/4/90 All holders of OLs
High Integrity Container or CPs for nuclear
Topical Report Review power reactors, fuel
Status, Identification cycle licenses, and
of Problems with Cement certain by-product
Solidification, and materials licenses.
Reporting of Waste Mishaps
90-30 Ultrasonic Inspection 5/1/90 All holders of OLs
Techniques for Dissimilar or CPs for nuclear
Metal Welds power reactors.
90-29 Cracking of Cladding and 4/30/90 All holders of OLs
Its Heat-Affected Zone in or CPs for nuclear
the Base Metal of a Reactor power reactors.
Vessel Head
90-28 Potential Error in High 4/30/90 All holders of OLs
Steamline Flow Setpoint or CPs for BWRs.
90-27 Clarification of the 4/30/90 All uranium fuel
Recent Revisions to the fabrication and
Regulatory Requirements conversion facilities.
for Packaging of Uranium
Hexafluoride (UF 6 ) for
Transportation
OL = Operating License
CP = Construction Permit