ML003739403

Procedures for Picking Up and Receiving Packages of Radioactive Material

ML003739403
Person / Time
Issue date:	05/31/1976
From:	Office of Nuclear Regulatory Research
To:
References
RG-7.3
Download: ML003739403 (10)

Text

U.S. NUCLEAR REGULATORY COMMISSION May 1S75 REGULATORY GUIDE OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 7.3 PROCEDURES FOR PICKING UP AND RECEIVING PACKAGES OF RADIOACTIVE MATERIAL A. INTRODUCTION conditions. Finally, § 20.201 states that, when appro priate, such evaluation should include a physical survey Amendments" to § 20.205, isILocedureSL for picking of measurements of levels of radiation or concentrations Up, receiving, and opening packages," of the Com of radioactive material present. External contamination mission's regulations in 10 CFR Part 20, "Standards for levels and external radiation levels near received pack.

Protection Against Radiation," require that a licensee ages should be considered unknown until surveyed. If who expects to receive a package containing quantities of the quantity and form of radioactive material in a radioactive material in excess of Type A limits make package is such that if the material were unpackaged, the arrangements to receive the package when it is offered licensee should take some action to comply with other for delivery at his facility by the carrier or, if the provisions of 10 CFR Part 20 (such as those dealing with package is routed to be. picked up by the consignee at limits on radiation exposure, restricting or posting of the carrier's facility, that the consignee make arrange areas, labeling of containers, or providing personnel ments to receive notification from the carrier at the time monitoring equipment to nearby persons), some form of of arrival of the package. A licensee who picks up a control should be established on receipt of the package.

package of radioactive material from a carrier's facility is An evaluation of an individual package which is exempt required to do so soon after being notified. As soon as from the more stringent provisions of § 20.205 can be practicable after receipt of a package and within delayed or perhaps even made unnecessary (1) by the specified time limits, licensees are further required to use of area monitors and/or restricting access to an monitor the external -surfaces of certain packages of incoming package or (2) by other means that ensure radioactive material for 'radioactive contamination and safety and compliance with the provisions of 10 CFR for external radiation levels, subject to the exceptions Part 20.

contained in Annex I to this guide. If an amount of contamination or radiation level in excess of that specified is detected, the licensee is required to immedi This regulatory guide describes a method acceptable ately report that fact to the final delivering carrier and to the NRC staff for licensees to comply with the to the NRC. These requirements are directed toward provisions in 10 CFR Part 20, § 20.205, with respect to control of radiation exposure and spread of radioactive arrangements for receipt, pickup, and monitoring of contamination from packages of radioactive material in packages containing radioactive material and with transport. respect to reporting of packages which, on receipt, show evidence of leakage or excessive radiation levels.

Section 20.201 of 10 CFR Part 20 requires each licensee to make or cause to be made such surveys as may be necessary for him to comply with the regulations B. DISCUSSION of 10 CFR Part 20. "Survey" is defined in that section as an evaluation of the radiation hazards incident to the Since there is no requirement that packages contain presence of radioactive materials under a specific set of ing radioactive materials be routinely monitored for leaks during transport, it is necessary that packages be picked up expeditiously and that the existence of a leak "dEffectiv date, May 22, 1974. be detected rapidly (1) to minimize radiation exposure USNRC REGULATORY GUIDES Comment$shefould be bent to the Secretar Of the Commission. U.S. 11kicteer Reuaoy s

id ited to describe and make available, to the public

.re ServSeulctonyCmtao.Wstgoi CUn teto okte i methods a ccetabl to the NRC staff of impiementing specific parts of the Setn CommissionsI regufat'ons to delineate lacftniques used by the staff in evalti The guides areilssuoedsnthe followington broad diviaions Problems or postulated accidents. or to provide guidance to agol centsspecific etaig Regulatory Guides sera not substitutesf tor rouaeufeioneand compliance I. Power Reactor& S Products with them.* not required Methods end solutions different from these set oul Ini Research and Teti Reactors 7 Trenapeortetfo t he guideswilt be acceptableittolhey provide.a basis for the findings requisite to 3 Ful en Mosesesiicifirtioee I occupettletrai 14661ti the issuance or conitriuance dt a permit or license by the Commission

4. Enirnena and S$ting S Antitrust Revisw Comments and suggestions lot improvemeints in these guides are encouraged 5 Materials and Plantt Protieltion 10 General at all times and guide* will be revised. as appropriate to accommodate com mefnts and, to reflect new information or experience Howelver, commienta on Copies of published guides may be obtained by written request windicating tMe

his guide If received within about two months after its issuance. wilt be par diviaions defrlsedi to the U S NucklearRegslator Commission. Washington, U.C.

ticularfy useful in evaluating the noed for arrearly revision ZSU. Attention Director.OfficoeftStndardrsaDevefpient

of transport personnel and licensee personnel, (2) to complying with the package pickup and monitoring minimize the spread of contamination, (3) to allow requirements of paragraphs (a), (b), and (c) of § 20.205.

identification of personnel, vehicles, property, and facili ties that have been exposed or contaminated during transport, expediting remedial action, (4) to minimize the time a package is in a carrier's facility and thus D. IMPLEMENTATION subject to accidents, and (5) to obtain evidence of a leak in a package other than the package being monitored.

The purpose of this section is to provide information Licensees receiving packages containing radioactive to applIants and licensees regarding the staff's plans for material have the responsibility to expeditiously pick up utilizing this regulatory guide.

the packages at carrier's terminals and to monitor the package's external surfaces for radioactive contamina Effective on publication of this guide, the method tion or excessive radiation levels, as well as to notify the described herein will be considered acceptable by the delivering carrier and NRC immediately if external Commission's staff in messing licensees' performance radiation or radioactive contamination in excess of that with respect to picking up and receiving packaes of specified is detected. radioactive material from carrier operations. Alternative methods that satisfy the requirements in the Annex I to this document contains a discussion* of Commission's regulations will also be considered the requirements of § 20.205 to sist licensees in acceptable.

understanding and complying with the regulatory requirements.

• This dicuseon h alo contained In a document entitled C. REGULATORY POSITION "Procedures for Pickin Up and Receiing Packages of Radio active Material," WASH-1313, June 1974. Copies may be The guidance contained in the NRC document, obtained from the National Teduncal Infonration Service, United States Department of Commerce, 5285 Port Royal "Procedures for Picking Up and Receiving Packages of Road, Springfild, Va. 22151, at a price of $4.00 for a printed Radioactive Material," constitutes an adequate basis for copy and $1.45 for a microfiche copy.

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ANNEX I PROCEDURES FOR PICKING UP AND RECEIVING PACKAGES OF RADIOACTIVE MATERIAL INTRODUCTION require a licensee who expects to receive a package containing radioactive material in excess of Type A The regulations of both the NRC and the Department limits* to arrange to receive the package when it is of Transportation (DOT) provide package design stand offered for delivery at his facility by the carrier or, if the ards and provisions for testing packages prior to ship package is to be picked up by the consignee at the ment to reduce to a minimum the chances of leakage carrier's facility, to arrange to be notified by the carrier during transport. Under the present regulations, of the arrival of the package at the time of its arrival. A however, carriers are not required to have radiation licensee ,who picks up a package of radioactive material monitoring capabilities. Therefore, the earliest opportu from a carrier's facility is required to do so expedi nity for monitoring (i.e., the first time packages in tiously. licensees are further required to monitor, as routine transportation channels are in the hands of soon as practicable after receipt and within specified persons equipped and trained in radiation monitoring) is time limits, the external surfaces of certain packages of at the consignee's plant. radioactive material for radioactive contamination and for external radiation levels. If greater than a specified The record over the past 25 years in the transporta amount of contamination or allowable radiation levels is tion of radioactive materials shows that procedures to detected, the licensee is required to immediately report control leakage from packages containing radioactive that fact to the final delivering carrier and to the NRC.

materials have been highly effective. In the shipment of millions of packages between the 1940's and early 1974, The requirement that packages be monitored on only about 100 or so containers are known to have receipt provides a positive means for detecting any leaked. significant radiation level or leakage from packages, substantiates the record of no leakage, and provides data Although in some of these incidents accident condi that can be a basis for changes in specific designs that tions caused failure of containers, several failures would further reduce the chance of high radiation levels occurred in the absence of an accident. In a few cases in which there was no apparent evidence of damage or leakage, there was considerable spread of contamination *Whether the quantity of a radionuclide exceeds Type A limits because the leakage went undetected for some time. may be determined as follows: The Type A quantity limits Also, in several cases, excessive external radiation levels differ for eight transport groups of radionuclides (Enclosure B),

were measured on a package on receipt. making it necessary to know what transport group(s) one or more radioisotopes is in. Radionuclides are, in general, assigned to transport groups accordifg to their radiotoxicity (see After one such contamination incident, the National Enclosure A). The most radiotoxic, such as the isotopes of Transportation Safety Board report of its investigation plutonium, are in Group I with a Type A limit of I millicurie.

noted that delays in pickup, monitoring, and reporting Group II, which includes radionuclides with radiotoxicity contributed to the spread of contamination. The NTSB equivalent to that of strontlum-90 and barium-1 33, has a Type A limit of 50 millicuries. Group' li, which includes radionuclides report pointed out that DOT authority does not extend with toxicity equivalent to many commonly used isotopes such to the consignee of a shipment of radioactive materials as cerium-144, cesium-137, iodine-131, and thallium-204, has a and recommended 'that the Commission impose a Type A limit of 3 curies. Group IV, which contains commonly requirement that licensees promptly pick up and moni used isotopes such as chromium-51. cobalt-S8, gold-198, molybdenum-99, and technetium-99, has a Type A limit of 20 tor packages of radioactive materials of the type curies. Groups V through VII an specialized groups including involved in that incident. inert gases such as krypton in uncompressed form and materials in low-hazard form such as tritium (H-3) as a gas or luminous Delays in reporting of leaking packages by consignees, paint.

either as a result of delays in transporting a package to "Special form" (see Enclosure B) is a specialized group which the consignee or delays in his recognizing that a package applies to many materials that are either in solid, nondispersible is leaking, may contribute to the spread of radioactive form or in a capsule that will retain its contents under contamination and to its economic and radiological prescribed conditions; the Type A limit for a radioisotope in consequences. Delays in reporting or failure to report special form is 20 Ci, as compared with a variety of Type A limits for radioisotopes not in special form.

excessive radiation levels may make it impossible or more difficult to assess and deal with any overexposures. If the radionuclide expected to be received is known, its transport group can be found in the list in Enclosure A, and the Type A limit can be found in the table in paragraph 20.205(b)

Amendments to § 20.205, "Procedures for picking of 10 CFR Part 20 (reproduced here in Enclosure B for up, receiving, and opening packages," of the Commis convenience). From this, it can be determined whether the sion's regulations in 10 CFR Part 20, "Standards for expected package contents will be in excess of the Type A Protection Against Radiation," that have been adopted limits.

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.or leakage occurring. These requirenients are directed potential accidents in the carrier's facility; i.e., the toward the control of (1) radiation exposure arid (2) longer the package remains at the carrier's facility and spread of radioactive contamination from packages of the more times it is handled, the greater the chance of its radioactive material in transport. involvement in an accident.

Expeditious movement to the consignee, combined with the monitoring required by paragraphs 20.205(b)

DISCUSSION OF REQUIREMENTS and 20.205(c) discussed below, provides the means for timely detection of any leaking package or otherwise

1. Arrangements for Receipt or Notification of Package unsafe package. The sooner detection and reporting Arrival occur, the more timely can be the remedial action to reduce the consequences of an unsafe package having There has been concern that, in the absence of a been in the transport system.

requirement for facilitating the t;ansfer between carrier and consignee, a package received after normal working 3. Prompt Monitoring of Packages hours on Friday might remain in the carrier's terminal over the weekend because of the carrier's inability to Significant contamination on the external surfaces of deliver to or even to notify the licensee. Thus, § a package may have been caused by leakage of either 20.205(a) of 10 CFR Parl 20 is intended to ensure that that package or another package stowed with it during the transfer of a package with greater than Type A transportation. Whichever the source, such contamina quantity of radioactive material from a carrier to a tion may have been spread in the carrier's vehicles and licensee is not delayed on that account. A primary facilities to other packages in the same transportation purpose of this regulation is to minimize the time these system. Prompt monitoring of packages on receipt by packages spend in the carrier's terminal so that packages the consignee and immediate reporting of any evidence with a relatively high potential leak hazard may be of significant contamination on the outside of a package monitored for external contamination within a reason will permit the carrier to identify the vehicles, facilities, ably short time after transportation. goods, and property involved which might also be contaminated. If there is evidence that persons may have

2. Expeditious Pickup of Packages received significant radiation doses (more than 500 mrem, in most cases, would be considered a significant The provisions of the regulations are intended to dose), it is essential that action be initiated at the earliest ensure that a package containing radioactive materials is possible time after exposure so that the exposure transferred from the carrier system to the consignee with conditions can be reconstructed, doses can be estimated, a minimum of delay. Most packages are delivered persons with significant exposures can be identified and directly to the consignee's facility, frequently by a local notified, and appropriate action can be taken to collect delivery service or sicond carrier. These packages must biological samples or to provide medical treatment be delivered "without unnecessary delay" (see, for where indicated.

example, 49 CFR Part 177, § 177.853 of the regulations of the Department of Transportation). It is important to monitor for high radiation levels and for evidence of contamination on both external and When the routing papers for a packagce of radioactive internal surfaces of each package to avoid unnecessary matenals arriving at the carrier's terminal facility desig exposure of personnel and spread of contamination in nate that the package will be picked up at that facility the consignee's facility. If a specified amount of external by the consignee, the carrier has the responsibility of contamination is found on a package, the situation promptly notifying the consignee that the package is should be treated as though that package were leaking, available to be picked up The new paragraph 20.205(a) even though the contamination may have come from of 10 CFR Part 20 imposes a requirement on the another package. For protection of the personnel and consignee to pick up such package expeditiously after facilities of the consignee, the package should be being notified by the carrier of its arrival. isolated, and radiologically trained personnel should be asked to assist. Persons who have come in contact with Expeditious movement of a radioactive mateial the package should be detained until monitored and package from a carrier's termirsal facility to the con released by trained personnel.

signee reduces the amount of radiation exposure of transport workers. In cases where the packages are held Many users of radioactive material follow the proce in areas occupied by the carrier's employees, radiation 6ure of thoroughly' monitoring each package before exposure is directly related to the time the package is bringing it inside the laboratory, hospital, or plant. Good held at the terminal Also. delays in pickup may result in health physics practice dictates that each package be extra package handling by carnei personnel and thus monitored inside and out while it is being opened and additional radiatioo exposure Expeditious pickup also before the packaging or the contents are moved away reduces the period of exposure of the package to from the utrpac king location 7.3"4

4. Immediate Notification package would not be sent from the originating carrier terminal to arrive at any other time. In this case, the If high external radiation dose rates are detected on consignee would need to maintain the capability to any package (i.e., either more than 200 mrem per hour receive notification or to receive the package (depending on the surface or 10 mrem per hour at 3 ft from the on whether pickup is required) only during those hours surface of a package) or if there are excessive contamina when pickup or delivery would be feasible. If the carrier tion levels on the external surface (i.e., more than 0.01 terminal is open 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week and there MuCi per 100 cm2 ), the NRC and the carrier who last had are no restrictions on when a particular package may contact with the package must be notified immediately. arrive, the consignee capability should be equally open

-ended, so that whenever the package arrives at the carrier terminal facility, the consignee is available to PROCEDURES either pick it up or receive it.

1. Procedures for Receiving Packages or Notification of In summary, the arrangements which the consignee their Arrival should make to receive a package or a notification that a package has been received at the carrier's facility depend Implementing the requirement to receive packages or in part on when the package may be or is likely to be to pick them up expeditiously has two aspects: (a) who received at the terminal carrier's facility. The arrange should make arrangements and (b) what arrangements ments should provide reasonable assurance that there should be made.

will be no undue delays in transferring a package containing more than a Type A quantity of radioactive

a. Responsibility for Arrangements. Only licensees who expect to receive quantities of radioactive material materials from the carrier to the consignee.

in excess of Type A quantities must make arrangements to receive a package or notification of its arrival at the 2. Expeditious Pickup of Packages carrier's facility.

In § 20.205 of 10 CFR Part 20, the word "expedi tiously" relative to picking up packages at the carrier's

b. Arrangements for Receipt or Pickup of Packages.

facility is not defined, permitting flexibility in individual When it is determined that arrangements for receipt or pickup of packages must be made, the arrangements are situations. In the following guidelines, an implementa tion of the requirement for expeditiously picking up ordinarily determined by the routing of the expected packages acceptable to. the NRC staff is described.

package, the working hours of the final delivering carrier, and arrangements the consignee has made with the supplier of the radioactive material. The pickup of a package containing radioactive material should be accomplished as soon as practicable In the simplest case, the licensee-consignee and his after receiving notification by the carrier that the supplier agree on a shipment time for the radioactive package is available.

material that will result in its arriving during normal working hours of the normal workweek. If the supplier a. If notice is provided during the normal workday, determines that this can be accomplished with a reason pickup should be completed the same day - if practi able degree of certainty and agrees to it, the consignee cable, within two or three hours.

need only maintain his ability to receive packages during his normal working hours; if routine shipments arrive on b. When notification by the carrier occurs after a regular schedule, this can be taken into account in normal working hours and it is not practicable to pick arranging for the capability to receive notification of the up or to arrange for pickup of a package from a carrier's availability of packages for pickup or in arranging to facility that same day, pickup should be accomplished as receive packages when delivered. If the supplier and early as possible the following morning. Here a distinc consignee arrange that the consignee will pick up a tion can be made between a package of radioactive package at the airport or at some other final delivering material of Type A quantity with its smaller potential carrier's terminal, the consignee should maintain, during hazard to people due to the smaller quantity and/or the normal working hours, the ability to be notified by the less hazardous nature of the contained radioactive carrier and to pick up the package. material and a package with a quantity greater than Type A with its greater potential hazards. If a Type B A more complicated case -would be an arrangement package is to be delivered, a special effort should be between the supplier and the licensee-consignee that made to take possession of it to the extent that a pickup allows shipment and arrival at any time or at a specific capability should be provided on weekends, holidays, time not during normal working hours In this case, the and other days that are not normal working days. Pickup working hours of the carrier at his terminal facilities of a Type A package, with its smaller potential hazard would influence the required preparations by the con and generally lower external radiation level, can be signee. If the carrier ierminal is open only from 8:00 postponed until the next normal workday. Type A and a.m to ý (X) , w' Pv, d. p,,

r-e Ji, e7 I*)npIe IhI "TypoB de-,ignations art, or soon will be. marked on the 7 3.5

outside of most packages containing radioactive Any removable radioactive contamination found need material. not be reported immediately if the average* amount of radioactive contamination as measured on the wiping material does not exceed 0.01 pCi (22,000 disintegra tions per minute) per 100 cm 2 of package surface area

3. Monitoring of Packages monitored.

Monitoring of a package to determine the external The phrase "as soon as practicable" as it relates to radiation levels is a simple procedure involving direct monitoring of packages also should be applied with measurement of the radiation level outside the package. flexibility. The consignee who picks up a package at the For purposes of satisfying the monitoring requirement in carrier's facility may choose to monitor the package paragraph 20.205(c), it is sufficient to make cursory while he is at the carrier's facility. That would certainly surveys around each package (1) at the surface and (2) at be "as soon as practicable." However, the application of 3 ft from the package with a Geiger-Mueller detector "as soon as practicable" to monitoring of packages by (unless a neutron emitter such as californium-252 or consignees normally will be determined in relation to the plutonium-beryllium is contained in the package, in time when the package arrives at the consignee's facility, which case a neutron detector should also be used). If whether delivered there by a carrier or brought there by the cursory survey reveals radiation levels well below 10 the consignee.

mrem per hour at 3 ft and well below 200 mrem per houiat the package surface, it is unnecessary to make a a. If the package arrives at the consignee's facility more detailed survey. during a normal workday, it should be monitored the same day - if practicable, within an hour or two of receipt. In any case, it is required that the package be If the preliminary survey indicates more than 10 monitored within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Because of the very low mrem per hour at 3 ft from any package, or more than probability that any individual package will be found to 200 mrem/hr at the package surface, a more careful be contaminated, it is not considered necessary to detain measurement of the levels is necessary. For the more the carrier who delivers a -package until a package is accurate measurements, the package being monitored monitored, unless the package is damaged or shows should be separated from other packages. If the packages evidence of leaking. The name of the delivering carrier are in a location where the background level of radiation should be kept available until the package has been is reasonably low and relatively constant, it might be monitored, however, since this carrier must be notified preferable to move the other packages away from the in the event significant external contamination is found.

package with the high external radiation levels. The levels should be measured (1) at the surface (i.e., by b. If a package is received at the consignee's facility placing the detector as close as is physically possible to after normal working hours and it is not practicable to the external surface of the packages which would be have the package monitored the day of receipt, the against a cargo handler-not, for example, between heat monitoring should be accomplished as early as possible radiation fins) and (2) 3 ft from the surface. An the following morning. In any case, the package must be appropriate type of survey instrument, properly cali monitored within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after receipt.

brated, should be used, and the radiation levels at the surface and 3 ft from the surface in all directions from the package should be accurately measured. The radia 4. Immediate Notification tion levels or a plot of isodose curves and the degree of accuracy of the measurements should be recorded. These .If external radiation or radioactive contamination**

results should be provided to the carrier and the NRC as in excess of that specified is detected on a package, the soon as available so that dosage calculations can be recipient must immediately notify the delivering carrier, made. i.e., the last carrier known to have handled the shipment before the consignee took possession of it. This carrier is normally identified on the freight bill. This notification Monitoring of a package for external surface contami to the carrier should be immediate - that is, as soon as nation normally involves a two-step procedure. First, a possible, after making sure that high radiation levels do wipe test is made of one or more representative sections exist or that the package is actually contaminated. This of the outer surface of the package. The wipe test is notification normally is by telephone. Because the made by rubbing a filter paper or other absorbent material over a predetermined area (usually about 100

• The average refers to the contamination from the specific area cm 2 or 16 in. 2 ) of the package surface, using strong wiped by the absorbent material up to 100 cmI and does not finger pressure. Second, the absorbent material is moved refer to the average contamination of multiple wipe samples.

to an area where the radiation level is at or near background, and any activity on the absorbent material **Levels well above those permitted on the surface of packages is measured with appropriately calibrated instruments. under the DOT regulations.

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carrier would take corrective actions in response to such §2U.205, and a record ot survey results is required1 by 10 a notification, the presence of high external radiation CFR Part 20, paragraph 20.401 (b).

levels or contamination should be definitely confirmed before notification - by checking the operation of the INSTRUMENTATION measuring instrument, by checking the radiation meas urements, by rewiping the package surface, by counting If only beta or gamma radiation is involved, the rough for a longer time period, or by whatever other confirma check of external radiation levels can be made with a tion seems appropriate for the procedure being used. Geiger-Mueller (GM) detector or counter. If significant levels of neutrons are possible, as in the case of a DOT regulations require that the carrier isolate any package containing californium-252 or polonium equipment and facilities that have been in contact with beryllium or plutonium-beryllium sources, a neutron the contaminated package and that he notify both the detector should be used in addition to the GM detector, Departmnnt of Transportation at 202-426-1830 and the and the sum of the measured levels should be considered consignor (shipper) of the package. The Department of in evaluating the level of radiation.

Transportation will accept this notification at any hour of any day. DOT will then take the initia.tive and, upon For more accurate determinations, a GM detector, determining whether widespread contamination is likely, ion chamber, scintillation chamber, or other accurate will work with the consignor and other carriers involved calibrated instrument appropriate for the type and levels to take what action is necessary to control the spread of of radiation to be measured should be used. Considera contamination and to properly deal with the contami tion should be given energy dependence, geometry, and nated vehicles, facilities, and property. other factors affecting the accuracy of the readings obtained with whatever instrument is used.

The appropriate NRC Regional Office (see Enclosure C) should be notified by the licensee to ensure that the Package surfaces normally are checked for contamina end carrier takes the required action to involve the tion by the wipe test procedures described above. The consignor and DOT in the*response to the incident, and level of contamination on. the wipe is measured with to provide technical advice and assistance where neces appropriate radiation-detection instruments.

sary. This notification, also, will be accepted at any hour of any day. Instrumentation needed to detect the levels of exter nal contamination specified in § 20.205 should be RECORDS readily available. A thin-window GM detector, either in a portable monitoring instrument or used in conjunction Any delay in detecting and reporting high external with a shielded counting chamber, should be sufficient radiation levels or a leaking radioactive material package in most cases to monitor for the levels of contamination may be important in (1) assessing the radiation doses to specified. A scintillation well-counter, normally used to people, (2) controlling the spread of radioactive con measure medical patient samples, would also normally tamination, and (3) limiting the costs in time, money, be adequate for this task. When external contamination and injury of its consequences. It is suggested, but not can be determined at these levels only by the measure required by the regulation, that a consignee's records ment of alpha radiation (e.g., if the contaminant is indicate when he was notified of the arrival of a package polonium-210), instrumentation to detect alpha radia and when it was picked up and monitored, including tion is necessary. Once the instrumentation and notations of reasons for delays if any. In the event a high procedures for monitoring a package containing specific radiation level or leakage is detected, records should be radionuclide(s) are established, the monitoring can be kept of persons notified and the time of notification. accomplished by a person with a minimum amount of radiological or monitoring training. There should, of The monitoring of incoming packages is a necessary course, be a trained person on call to assist if there is an survey under the provisions of 10 CFR Part 20, unusual instrument response.

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ENCLOSURE A Transport Grouping of Radionuclides (from 10 CFR Part 71, Appendix CM Elemsent, Raodioncsllde"" Group El..mnt 111114o...Ci~deGroup Elemient I PAd~gdiflcioeii Cge Asctinium (89) -. Ac 227...........I Ividium(77)... Ir 190........... IV Strontium (38) SeSI5 m.......... IV Ac 228...........I Ir 192........... III Sr as............ IV Americium (9S) Am241........... I Ir 194.......... IV So s9............

Am 243........... I Iron(26) .... Fe 55........... IV Sr go............ III Anstimtony (St1) Sb 122........... I Fe 59........... IV So 91............ Ill SA;t24........... I skrypton(36) ... KrS i5m..... IlI Sir92............ IV Sb 125...........I Kr 85 mn(uncom. V Sutphur(16) . SeSS . .. .. . IV Argon (I A) pressed). Tantalum (73).. Ta 182..........

Ar.41............ I KISS........... Technetium (43).. Tc %in..... III At..41 (uncom Kr 85 (uncoin. III Tc:96........... IV pressed) VI 1c 9'? ... . . IV Arsenic (13) As 73 . . . . . Zireeed).

Kr7......... Tc 91. ý.... IV As 74 . .. . Kr 87 (uncom. Te" m .... &V At 76...... preased). I IV Tc 99 . . . . . IV As 77 l.anthanum (57). Las140.......... IV Telluriumt (S2) To (25 mn IV Astatine (85) .. Lead (82) ... Pb 203 .. . . . Ta 127 mn IV Barium (56)... Bts131.......... Pit210 . .. . . IV T: 121 ...

Ba-I33 .. . . . Pb212 .. . . . To 129 m.... IVI IV Ba ,140.......... Lutecium (7 1).. Lu 172.......... IV Te 129 ... . . III Bellrkeltum (97) -. Bk 240.......... Lu 177.......... III To 131 in.... IV Beryltiurn (4) .. Magnesium (12) Me 28 . . . . . IV To 132 .... fIl Bisimuth (83)1.. Bi 206...... Manganese (25) Mn S2 . . . . . IVl Terbium (65) .. Th 160.......... IV Bi207 . . . . . Mn54 . . . . . IV Thallium(81) 1I1200........... III N110.......... Mn S6...... IV TI 201........... IV Bi2l2........... Mercury (80) ... HS 197 mi ... IV TI 202........... IVI Bromine (31) .. Br 82............ HS 197 .. . . . IV T1 204...........

Cadmium (48) -. Cd 109 ..... Hg 203..... 1V Thorium (00) .. Th 221.......... III Mixed ("saon prod. Tb 220..........

Cd Ilis.......... ucts Mrp. Th 230..... Itl Calcium (20) .. Coos........... Molybdenum (42) Mo 99........... Th 231..... II

• a41........... Nood riium (60). Nd 147 .. . . . 7% 3233.........

Californium (98) Cf 349 .......... Nd 149 .. . . . Th 234..........

(f212 ...... Neptunium (93) Np 237 L.. . . Tb Natural ...

Np 239..... Thulium (69) .. Tmn16$8 .... fit Carbon (6)j.... Ct4.. .......... Nisi56...........

C14t........... Nickel (28) Tm 170 .....

Cer~um (58)... NiS9 ........... Tmn 171.......... III IV

,Cn 143.......... Ni63 .. . . . . Tin (50) Sri 13 .. . . . IV Cc 144.......... Nis 6........... Sr 17 m .... III Cesium (55)... Cs 131...........

4 Niobium (41) ... Nb 93 m L.r.. Sri121 .. . . . III Cs13 mn..... Nb 95 . .. . . Sn 12S.......... IV 5&134 .......... Nb 97 . . . . Tritiorn (1t) H-3............. IV Cs13S .......... 0smium (76) .. O6)s 85 . . H 3 (asasm gasu C& 136 .......... Os 191 m .. Iumninuut paint.or Cs 137 . . . . . 0s 191 .. . . . adsorbed on sulid Chlorine (17) .. C136 ........... 06 193 .. . . . material) . . . . VII CI38............ Palladium (46).. Pdt103 .. . . . Tungsten (74) WIII Chromium (24) Cr 51 .. . . . . Pd lo10 . .. . IV IV Cobalt (27) Co 56........... Phosphorus (15) P 32 IV CoS7........... Platinum (78) Pt (91 Uraium (92) U 230...

ii Sa8 . .. . . Pt (93 .. . . U 232 ...

Co 51 .. . . . Pt 193 m .. U 233 (F) . . . . It Pt (97 Min .. U 234 . . . . . It Copper (29). Cu64........... Pit 197...... U 235 (F).... III Curium (96)... Cm 242.. Pluitontium (94) Pu 238 (F) U 236 Cm 243.. Pu 239 (F) U 239 . ..

Cm 244.... Pu 240 .. . . U Natural....

Cm 24S .... 24 (F) U Enriched (F) ... III Cot246 . Puu 22421 U Depleted..... III D~ysprosium (66) Dy 154 .. . . . Polonium (114, Vanadium (23) V49......... .. III Dy 163 .. Potassium(09) PK422 V 49 .. . . . .

Dy 166 .. . . . K43.. Xenon (541 Xe 1251 . . . . IV Etblum (68) Er 169 . .,. Praseodyntium (59) Pr 142. X. 131 M..

Er 171...... ... . P" 143 . . . Xe 131 mn III Europium (63) liv ISO .. . . . Promtthiunr 61) Pm 147 (uncompressaed).VIl Eu 112 in Pm 149 Xe (33 .. . . .

Eu 152 Protactinium(9)1)P4 230 Xe (33 V Pa 231' (uncompreesod).

Fluorine (9)... Eu 155 Pa 233, Xe 13S IV' Radium (661 Re 223 Xe 135 Gadolinium (64) Gd 153 Ra 224 (uncompreessd). III Get 59 . . . Ra 226 .. Ytterbium (720) Yb VF . .7 .. IV Gallium (31t) GA67 Rtu228 Yttrium (39) Y 1111. . ..

Go72 . . . Radon (86) Rn 220 Y 90 .. . . . . III Germanium (32) Ge 71 . . Rn 222 .. Y9 1 . .. .. IIl Gold (79).... Au.193 .. . . . Rhenium (75) Re (83.. Y 91 .. . . . . IV Au (94... Re l b .. .. . Y 92............ IVI A u (95 .. Re (87 Y 93 .. . . . . ItV AuAt99196 Re III Zinc (30) Zn 65 .. . . IV IV Re Natural Zn 69 in Au I99 Rhodium 445) Rh 103 in .. Zn 69 IV Hlrunum (72) HrI 8( Rh Jos Zrirconhium (40) Zr 93 III Holmium (67) Ho (66 Rubidium (37) Rb 86 Z19S IV Hydrogen (1) H 3 (seetritium) Rh 87 ZY97 Indium (49) In t 13 in Rb Natural In 114 In Ru 97 In ((5 Rvir (3 *Atomic number shown Int parentheses 4An4,ur Ru 105 h( -Uncomprress~ed means at a pressure no loidin. t S') :nI24.1 Ru (06 exceeding ont atmosphere.

SM 145 . Atomnic weight ito-n after thi,rpdio 1126 Sm 147 nuctide symbol.

1,129 Sm is] et-Metastable ostae 131 Sm I (r) Fissile material 1((32 Sc 46 1133 Scu4' i134 SC41k Seltnium W3 Se,'

S, As 105 Alt I ;D A4 'I!

No!)

13 8

ENCLOSURE B Exempt and Type A Ouutly Limits (from amended § 20.206, 10 CFR Part 20)

Exemptb Type A Quantity Limit Quantity Limit Transport Group' (in millicuries) (in curies)

I. .................................... 0.01 0.00 1 11 . .................................... 0 .1 0.050 III . . . . . . . . . . .. . . . . . .. . . . . . . . . . . . . .. . . 1 3 IV ................................... 1 20 V .................................... 1 20 VI ................................... 1 1000 VII .................................. 25,000 1000 Special Form a .......................... 1 20

'The definition of "transport group" is given in § 71.4 of 10 CFR Part 71. "Special form," also defined in § 71.4, means any of the fol lowing physical forms of licensed material of any transport group:

(1) The material is in solid form having no dimension less than 0.5 millimeter or at West one dimension gpeater than five millimeters; does not melt, sublime, or ignite in air at a temperature of 1,000' F; will not shatter or crumble if subjected to the percussion test described below; and is not dissolved or converted into dispersible form to the extent of more than 0.005 percent by weight by immersion for 1 week in water at 680 F or in air at 86* F; or (2) The material is securely contained in a capsule having no dimension less than 0.5 millimeter or at least one dimension peater than five millimeters, which will retain its contents if subjected to the tests described below and which is constructed of materials which do not melt, sublime or ignite in air at 1,475* F and do not dissolve or convert into dispersible form to the extent of more than 0.005 percent by weight by immersion for I week in water at 68° F or in air at 86* F.

(a) Free Drop - a free drop through a distance of 30 feet onto a flat essmntially unyielding horizontal surface, sutkng the surface in such a position a to suffer maximum damage.

(b) Percussion - impact of the flat circular end of a 1-inch-diameter steel rod weighing 3 pounds, dropped through a distance of 40 inches. The capsule or material shall be placed on a sheet of lead, of hardneas number 3.5 to 4.5 on the Vickers scale, and not more than 1-inch thick, supported by a smooth, essentially unyielding surface.

(c) Heating - heating in air to a temperature of 1,475* F and remaining at that temperature for a period of 10 minutes.

(d) Immersion - immersion for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in water at room temperature. The water shall be at pH 6-8, with a maximum conductivity of 10 micromhos per centimeter.

bpck*ges containing a quantity of radioactive material not exceeding the pertinent exempt quantity need not be monitored under the provisions of § 20.205.

7.3-9

ENCLOSURE C UNITED STATES NUCLEAR REGULATORY COMMISSION REGIONAL OFFICES Telephone Region Address Daytime Nights and Holidays I

Connecticut, Delaware, District Region I, Office of Inspection 215-337-1150 215-337-1150 of Columbia, Maine, Maryland, and Enforcement, USNRC, Massachusetts, New Hampshire, 631 Park Avenue, King New Jersey, New York, of Prussia, Pennsylvania Pennsylvania, Rhode Island, 19406 and Vermont II Alabama, Florida, Georgia, Region II, Office of Inspection 404-526-4503 404-526-4503 Kentucky, Mississippi, North and Enforcement, USNRC, Carolina, Panama Canal Zone, Suite 818, 230 Peachtree Puerto Rico, South Carolina, St. NW., Atlanta, Georgia Tennessee, Virginia, Virgin 30303 Islands, and West Virginia III Illinois, Indiana, Iowa, Region I11,Office of Inspection 312-858-2660 312-739-7711 Michigan, Minnesota, and Enforcement, USNRC, Missouri, Ohio, and 799 Roosevelt Road, Wisconsin Glen Ellyn, Illinois 60137 IV Arkansas, Colorado, Idaho, Region IV, Office of Inspection 817-334-2841 817-334-2841 Kansas, Louisiana, Montana, and Enforcement, USNRC, Nebraska, New Mexico, 611 Ryan Plaza Drive, North Dakota, Oklahoma, Suite 1000, South Dakota, Texas, Arlington, Texas 76012 Utah, and Wyoming V

Alaska, Arizona, California, Region V, Office of Inspection 415-486-3141 415-273-4237 Hawaii, Nevada, Oregon, and Enforcement, USNRC, Washington, and U.S. Suite 202, 1990 N. California territories and possessions Blvd., Walnut Creek Plaza, in the Pacific Walnut Creek, California 94596 7.3-10