ML19247A826
| ML19247A826 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1979 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Bradford P NRC COMMISSION (OCM) |
| References | |
| RULE-PR-71 SECY-79-12, NUDOCS 7908020493 | |
| Download: ML19247A826 (2) | |
Text
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NUCLE AR REGULATORY COMMISSION WASW NG TC N, D. C. 70555
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p JU.N 2 P 1,5 MEMORA!!DUti FOR:
Commissioner Bradford Lee V, Gossic k 6*W * **
THRU:
Executive Director for Operations FROM:
Robert B. Minogue, Director Office of Standards Development
SUBJECT:
SECY-79-192 - PROPOSED REVISION OF 10 CFR PART 71 " PACKAGING OF RADI0 ACTIVE MATERI AL FOR TRANSPClT AND TRAliSPORTATION OF RADI0 ACTIVE MATERIAL UNDER CERTAIN CONDITIONS" This is in response to your cccclents on the subject paper forwarded on May 14, 1979 to the Secretary of the Commission.
Your first ccmment was "I would delete the general license for materials in DOT approved containers because I do not think DOT has a meaningful licensing pro-gram".
You are ccrrect that current DOT package reviews are limited to a brief examination of package designs already approved by another regulatory agency.
As such, the DOT review by itself would not be sufficient to support the general licenses in 10 CFR 71.12.
The NRC general license in Section 71.12(a), however, authorizes only the use of DOT specification containers which, under the terms of our Memorandum of Understanding with DOT. nust receive fiRC approval before publication in DOT regulations.
The NRC general license in Section 71.12(c) authorizes only the use of packages which have been approved by a foreign national competent authority prior to its DOT review.
The general license limits its authority in this case to import and export shipments.
In each of these cases, since the primary safety review is completed by a separate regulatory body, with the DOT function prinarily that of admini.stration, we believe the NRC general licenses in 10 CFR 71.12 are justified.
Your second ccament was "Any individuals cccupying areas (p. 74, 71.54, 6.2 iv) where radiation exceeds 2 mrem /hr should be trained in accordance with 10 CFR 19.12".
As with our own regulations in 10 CFR Part 20, the basic goal for limits on radiation levels prcduced from transportation are intended to prevent members of the general public from receiving radiation exposures in excess of 500 mren/;,r.
In the cited reference, the 2 mrem /hr limit is applied for those cases of sole-use vehicle transport where the radiologically-ccmpetent shipper is in a position to control the conditions of shipment, including radiation levels.
In nonsole-use vehicle transport, the truck crew is normally not expected to be associated with radioactive material shipments for large fractions of their working hours, so that regulatory separation distances and the shielding effects of other cargo are expected to provide adequate protection.
In nonsole-use vehicle transport, there is noru1 ally no radiologicclly trained person available to measure radia-tion levels when trucks are loaded. We have worked on the premise that our goal kN
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79080209'97
Commissioner Bradford is to provide reasonable assurance that transport worker whole body exposure is in most cases held below 500 mrem /yr, with further reductions as possible under the ALARA principle, and that the 2 mrem /hr seconda,y limit need not be applied to all aspects of transportation.
Surveys of radiation exposures to persons in the transportation system over the past few years have confirmed that exposures to passengers, attendants, and crew in passenger aircraft are low, end exposures to cargo handlers in airports are also low. A few instances have been found where exposures to handlers and drivers in road carriage would exceed 500 mrem /yr where large numbers of radiopharmaceutical packages are funneled through one carrier location.
Where these instances resulted from noncompliance they have been correc ted.
In other cases a competent health physicist was already employed to control exposures and instruct pe~rsonnel.
To cou. der those situations where exposures to transport workers exceed general public guidelines even when DOT rules are followed, we are working with DDT staff to devise a system for better identific? tion and control.
Since a large fraction of packages in normal transportation create radiation levels in excess of 2 mrem /hr, it would not be practical to radiologically train the large number of people who might enter such a radiation field for a short period of time.
Our survcys provide reasonable assurance that radiation doses in such cases are very small because of the short times involved. We have in the past years studied the impacts of reducing package radiation levels in transportation and made recoumendations for reductions where justified.
Because of practical considerations in transportation, however, increased package shielding to reduca external radiation levels has an indirect financial impact on a large segment of the population who undergo radiological diagnosis and treatments.
Consideration of this and other factors will be included in our efforts to apply ALARA to transportation standards, an effort scheduled to begin in FY 1981.
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Robert B. Minogue, Director Office of Standards Development cc:
Chairman Hendrie Commissioner Gilinsky Commissioner Kennedy Commissioner Ahearne 48Y l2
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