ML19332F990
| ML19332F990 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1989 |
| From: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ashley Roberts TRANSPORTATION, DEPT. OF |
| References | |
| NUDOCS 8912200010 | |
| Download: ML19332F990 (4) | |
Text
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f DEC 121989 DISTRIBUTION:
NRC F/C. PDR CMacDonald JCook RBurnett HMSS/SGTB r/f
- fir Alan I. Roberts, Director Office of, Hazardous Materials
. Transpo'rtation U.S.-Department of Transportation 400 Seventh Street, S.W.
Washington, D.C.
20590 Dear Mr. Roberts!
I am. responding to the letter dated September 26, 1989 from the Radioactive Materials Branch of your office requesting comments on the International Atomic Energy Agency's (IAEA) regulatory provisions for the safe transportation of large quantities of radioactive materials _by air.
As a general coment, we support the view that the proposed mode.related regu-
- latory provisions should apply to all radioactive materials.~ As you know, a proposed rule published on June 8, 1988.would codify the qualification criteria" forplutoniumairtransportpackaging(containedinNUREG0360)?in10CFRPart 71.
In this regard, it should be understood by the IAEA and others that require-ments-similar to those in NUREG 0360 apply to air. shipments of plutonium enter.
ing-the U.S._ Our specific coments on the IAEA provisions are enclosed.
We appreciate this opportunity to comment on proposed IAEA regulatory provisions affecting theLtransportation of-radioactive materials. We will be pleased tot work toward presenting a clear picture of' the U.S. regulatory position 'on these matters to IAEA.
p Q,-.
bA Robert F. Burnett, Director Division of Safeguards and Transportation, HMSS
Enclosure:
As stated ii j
cc:
1-ir._ Michael E. Wangler Department of Transpo_rtation t
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gg NRC Coments.on.lAEA Transportation Regulatory Provisionss Enc 1 to ltr dtd: DEC12. W Concerning the items identified by IAEA on which consensus does not exist, our comments are as follows:
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a) the need for and design of a fireball test; We can not identify a technical justification for this test. The f_
sustained fire test already required has been shown in rail move studies to provide a greater heat load to the package than would a fireball test, b) the need for and design of a puncture and tearing test and its position in the test sequence; Puncture and tearing can occur in aircraft crashes. Specific tests would be helpful. The tests would precede the burn phase.
l-c) the need for and design of a crush test; Crush forces are a factor in aircraft crashes and need to be consi-dered. However, the design for an appropriate test is difficult due to variations in aircraft and nature of other cargo. An administra-tive control that requires no heavy cargo be placed behind the pack-age or a dynamic impact and crush test should be developed.
d) the need for and design of a burial test; With the ;dvent of higher package payloads and resulting heat loads, a burial test may need to be considered.
Our coments with regard to the items for consideration at the Advisory Group Meeting scheduled for 1990:
a) defining allowable external radiation levels after tests; We could support use of criteria that are acceptable for Type A packages.
l b) including an impact test at package terminal velocity in place of the L
85 m/s test; We would not object to an impact test at terminal velocity on a hard surface.
However, the test would only be required as an individual test when the terminal velocity of the package is greater than the re-quired impact test. The issue of use of drag enhancement devices to reduce terminal velocity should be considered.
ENCLOSURE 1
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c) inciuding the imersion test currently used for water-borne ship-ments and whether an imnersion test should follow the impact test at 85 m/s; Use of an imersion test is bppropriate. This should be an indi-vidual test. We do not believe this test :hould follow the impact test since impact with a "ard surface is unlikely to be followed by deep immersion, j
o d) reviewing the proposals concerning criticality Lafety as detailed in the Chairman's Report of the Seventh Menir.g of SAGSTRAM; We do not believe the proposals wart unt further consideration.
Established criticality controls are acceptable, e) whether there is a reason to incorporate a "non-dispersible" form definition in the the Regulations or whether this feature can be j
handled within the measurement verification of the release limit for the A / week; 2
A "non-dispersible" form alternative definition and test might be useful.
The definitioni and test conditions should be similar to the j
p test conditions required for the package.
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I DISTRIBUTION-i NRC F/C PDR CMacDonald JCook NMSS/SGTB r/f Mr. Alan I. Roberts, Director
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Office of Hazardous Materials i
Transportation U.S. Department of Trar.sportation 400 Seventh Street, S.W.
Washington, D.C.
20590
Dear Mr. Roberts:
I am responding to the letter dated September 26, 1989 from the Radioactive Materials Branch of your office requesting comments on the' International Atomic Energy Agency's (IAEA) regulatory provisions for the safe transportation of large quantities of radioactive materials by air.
As a general comment, we support the view that the proposed mode-related regu.
latory provisions should apply to all radioactive materials. As you know a proposedrulepublishedinJune8,1988wouldcodifythequalificationcrIteria for plutonium air transport packaging (contained in NUREG.0360) in 10 CFR Part 71.
In this regard, it should be understood by the IAEA and others that require-ments siinfler to those in NUREG 0360 apaly to air shipments of plutonium enter.
ing the U.'.
Our specific conenents on t1e IAEA provisions are enclosed.
We appreciate this opportunity to comment on proposed IAEA regulatory provisions affecting the transportation of radioactive materials. We will be pleased to work toward presenting a clear picture of the U.S. regulatory position on these matters to IAEA.
Robert F. Burnett, Director Di,'sion of Safeguards and Transportation, NMSS
Enclosure:
As stated i
cc: Mr. Michael E. Wangler Department of Transportation I
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