ML19329E389

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Forwards IE Circular 78-03, Packaging Greater than Type a Quantities of Low Specific Activity Radioactive Matl for Transport. Action Not Required
ML19329E389
Person / Time
Site: Midland
Issue date: 05/12/1978
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Howell S
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8006120703
Download: ML19329E389 (1)


Text

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s (CENTRAL Fl[Es r-MAY 121978 Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATIN:

Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, MI 49201 Gentlemen:

The enclosed Circular No. 78-03 is forwarded to you for information. No written response is required. Should you have any questions related to your understanding of this matter, please contact this office.

Sincerely, James C. Keppler Director

Enclosures:

1. IE Circular No. 78-03
2. Listing of IE Circulars Issued in 1978 cc w/encls:

Central Files THIS DOCUMENT CONTAINS

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P00R QUAUTY PAGES Director, NRR/ DOR PDR Local PDR NSIC TIC Ronald Callen Michigan Public Service Comeission Dr. Wayne E. North Myron M. Cherry, Chicago

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IE Circular 78-03 May 12, 1978 i

PACKAGING GREATER THAN TYPE A QUANTITIES OF LOW SPECIFIC ACTIVITY RADI0 ACTIVE MATERIAL FOR TRANSPORT This circular describes a situation that has occurred at nuclear power facilities and that could occur wherever greater than Type A quantities of low specific activity (LSA) radioactive material are packaged for transport.

Some licensees subject to the requirements of 10 CFR Part 71 have shipped packages containing greater than Type A quantitiss of LSA meterial in packages which are not authorized by NRC. These unautho-rized shipments have resulted from inadequate understanding of Part 71 regarding LSA material. Differences between Part 71 and the Departmant of Transportation requirements in 49 CFR Parts 170-189 have apparently contributed to these misunderstandings.

Specifically, 49 CFR 173.392 authorizes the shipment of LSA material in " strong, tight packages" when transported in vehicles assigned for the sole use of the consignor. DOT regulations make no mention of the total ac:ivity that may be shipped in this manner. On the other hand, NRC regulations (10 CFR 71.3) require that no licensee shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed material except as authorized in a general or specific license issued by the Commission, or as exempted in Part 71. The general license of 10 CFR 71.12 has requirements for the type of container when more than a Type A quantity of radioactive material is to be transported. LSA material in excess of a Type A quantity is not exempt from the general license requirements. Several licansees have failed to recognize the difference in the DOT and NRC requirements and have packaged greater than Type A quantities of LSA material for transport in containers other than those authorized by the general license of 10 CFR 71.12.

Compliance with Part 71 is the responsibility of the NRC licensee who delivers licensed material to a carrier for transport or who transports such material outside the confines of his plant or other place of use.

No written response to this Circular is required. If you require go additional information regarding this matter, contact the Director of

  • p the appropriate NRC Regional Offica.

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IE Circular 78-03 5

May 12,1978 fl LISTING OF IE CIRCULARS ISSUED IN 1978 Circular Subject First Date Issued To No.

of Issue 78-01 Loss of Well Logging 4/5/78 All Holders of Source Well Logging Source Licenses 78-02 Proper Lubricating 011 4/19/78 All Holders of for Terry Turbines Reactor Operating Licenses or Construction Permits i

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