ML19351G429
| ML19351G429 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/1981 |
| From: | Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Engelken R, Grier B, James Keppler, James O'Reilly, Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8102230691 | |
| Download: ML19351G429 (2) | |
Text
T't.,
ph h
~
[y {l
\\
M"y 1
~
M20 6
w.s.q$78" k.[_Flsi January 19, 1981 N T MEMORANDUM FOR: B. H. Grier, Director, Region I J. P. O'Reilly, Director, Region II J. G. Keppler, Director, Region III K. V. Seyfrit, Director, Region IV R. H. Engeiken, Director, Region V FROM:
Harold D. Thornburg, Director, Division of Safeguards and Radiological Safety Inspection, IE
SUBJECT:
TRANSPORTATION OF RADIOGRAPHY DEVICES The subject notice is enclosed for issuance on January 23, 1981.
It should be issued to all radiography licensees.
A draft copy of the transmittal letter, mailing labels anu licensee address printout are also enclosed.
Harold D. Thornburg, Director Division of Safeguards and Radiological Safety Inspection, IE
Enclosures:
1.
Draft transmittal letter 2.
IE Information Notice No. 81-02 3.
Mailing labels 4.
Licensee address printout O
CONTACT:
A. Grella, IE 49-28188 WPU:JD RSB:IE RSB:IE D
1/1/81 AWGirella LHigginbotham H g
INFOR4(A) 1/ /80 1/ /80 1/
81022 3 0 M (
1 i
(Draft transmittal letter for IE Information Notice 81-02 to all radiography i
i licensees) 1 l
IE Information Notice So. 81-02: TRANSPORTATION OF RADIOGRAPHY DEVICES J
Addressee:
I, l
The enclosed Information Notice No. 81-02 is forwarded for your information and guidance in the requirements for safe transportation and carriage of radiographic
)
devices.
If there are any questions related to this notice, please contact this i
i office.
1 I
Sincerely, 1
1 l
i Signature
{
(Regional Director)
Enclosures:
l.
IE Information Notice No. 81-02 2.
Recently Issued IE Information Notices t
i l
4 e
i l
1
.r-,--.
+., _, -,, *,..,, ~ -,
,o.,_..
-em.--m
,,,-,,v.,,,.
,--were..,_.v-,
r...
3.y.
..y--f.y.,,,,,.w.mr.,um.,~.,w,y,,---,y
,y-~,,,..,,7.-,,..
1 l
SSENS No.:
6870 Accession No.:
808220287 IN 81-02 UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 January 23, 1981 l
IE Information Notice No. 81-02:
TRANSPORTATION OF RADIOGRAPHY DEVICES l
Background:
Recent inspections by NRC have identified frequent noncompliance with trans-portation regulations by radiography licensees. As of December 3,1979, the NRC inspection program has included inspection / enforcement of 00T regulations in 49 CFR 170-178 as direct NRC requirements (see 10 CFR 71.5).
t The nature of radiography operations is somewhat unique in that radiography devices most frequently serve a dual function; that is, they serve as operational radiography cameras / source changers and as transportation packages.
Historically, this has caused some confusion on the part of radiography users, particularly with respect to sorting out the transport l
regulatory requirements of 49 CFR/10 CFR 71 from the operational requirements of 10 CFR 34 and the specific license which has been issued to the i
radiography user.
Another source of confusion for the radiography operator is that he most frequently functions, with respect to the transportation regulations, in the dual role of both shipper and carrier.
This notice discusses some of the pertinent transportation requirements for radiography devices when used as transport " packages." The explanations should help ou clarify the app'ication of operational licensing requirements l
Versus transport requirements applicable to shippers and carriers, thereby enhancing regulatory compliance with the requirements.
Discussions:
Source Design -- Radiography sources contained within a device are always encapsulated (Co-60 or Ir-192) and, therefore, meet the physical integrity requirements of "special form" as defined in 49 CFR 173.389(g) and 173.398(a).
Radiography transporters are reminded that these requirements call for each shipper of a special form source to maintain a file of supporting safety l
analysis or documentation containing the results of the testing performed on the source to demonstrate that it meets the special form requirements.
This does not mean that each shipper has to actually perform the tests, only that he obtain and retain the documentation of the tests.
As a p-actical matter, l
each radiographer should establish in his records a file of such data for each i
source design in his inventory.
It may be necessary, therefore, for the radiographer to request the required information from his source supplier.
1
l l
IN 81-02 January 23, 1981 4
Page 2 of 5 1
)
Package Design -- Radiography sources in snecial form will constitute a Type B J
quantity when in excess of 20 ci, with Type B packaging required for transpor-tation purposes. An exception to this rule is the 00T Specification 55 l
(referred to as " Spec. 55") which is not necessarily a Type B package (see 49 CFR 178 250; note that DOT no longer includes this specification in its annual printing of 49 CFR).
Spec. 55 (see Appendix A) is authorized for limited Type B quantities (up to 300 ci) of special form radioactive materials 1
in domestic shipments only [see 49 CFR 173.394(b)(1)].
Under this pro-vision, however, only Spec. 55 devices that were constructed prior to March 31, 1975 are authorized (00T has recently announced its intention to j
" phase nut" 00T Spec. 55; see 44 Federal Register 1852, Part II, January 8, 1979.)
For those radiography devices that exceed 20 Ci activity and are not contained d
in DOT Spec. 55, an NRC Certificate of Compliance (C0C) must be issued pursuant i
to 49 CFR 173.393a and 173.394(b)(3).
Such approved designs may be used by 1
other than the origirial COC applicant provided that such user registers with i
tne NRC Office of Nuclear Materials Safety and Safeguards (NMSS), has a copy of the applicable CCC, and complies with its terms and conditions [see 10 CFR 71.,2(b)].
A listing of radiography cevices for which NRC has issued a COC i
is given in Table 1 (see Enclosure 2).
Copies of COCs are included in the NRC/NMSS reports, " Directory of Certificates of Compliance for Radioactive Materials Packages" (NUREG-0383), which is updated annually.
CAUTION:
The fact that a radiography device has been approved by NRC under a specific license provision pursuant to 10 CFR Part 34 as an i
operational cevice does not r.ean that it has been approved as a Type B transoort package pursuant to 10 CFR Part 71.
Specification Overpacks -- Pursuant to 49 CFR 173.394(b)(5) and (6) and 173.394(c)(4), Spec. 55 packages may be used to transport quantities of of activity exceeding 300 ci (domestic service) or 20 ci (international service), provided that a Spec. 20 WC (49 CFR 178.194) or Spec. 21 WC (49 CFR 178.195) protective overpack is used.
Again, however, this authorization is restricted to the use of Spec. 55 packages constructed prior to March 31, 1975.
For international shipments, shippers must additionally register as a user under the applicable DOT Certificate of Competent Authority issued by. that agency pursuant to 49 CFR 173.393b.
00T further requires that this certificate be supplied to the foreign consignee and Competent National Authority of the destination country.
Type A Packages -- For radiography devices r.ot exceeuing 20 ci of activity as special form, tne applicable transport specification is either DOT Spec. 7A 3
[49 CFR 173.394(a)(1) and 178.350] or Spec. 55 [49 CFR 173.394(a)(2) and 178.250].
For Spec. 7A, as in tne case of a special form source, 001 regulations require that each shipper of a Spec. 7A package maintain on file 1
written documentation attesting to the results of the Spec. 7A performance tests performed on the package design [49 CFR 173.394 (a)(1)].
j IN 81-02 January 23, 1981 Page 3 of 5 If the shipper of a Spec. 7A ~ package is not the original designer or user of that package, it will be necessary for the shipper to obtain the test report data from the original supplier / user or to perform the tests.
l Package Labeling -- Each radiography device (package) must be properly labelled l
with the appropriate category of RADIOACTIVE label in accordance with 49 CFR 172.403(a) through (d).
This requires affixing two labels, with one label on each of two opposite sides of the package, based on the radiation dose rates at the surface and at 3 ft (transport index) from the package. The dose rates are limited to 200 mrem /hr at contact with any point on the external surface of the package and 10 mrem /hr at 3 ft from any point on the surface [49 CFR i
173.393(i)].
I A question frequently arises regarding the labeling of radiography devices when enclosed in an outer " convenience" box, enclosure, foot locker, etc., during transportation.
The question is whether or not the radiation levels at the
)
surface of such an outer enclosure may be used to establish the labeling i
requirements for the overall " package." Since this situation is not addressed in 49 CFR, it is permissible to use such enclosures and to establish labeling on the basis of the dose rates at the exterior of the outer enclosure.
1 j
Assuming that the inner enm;ionent (the device) is a proper DOT Spec. 55 device i
or is designed according to NRC/C0C requirements, and is marked as such, the 4
outer enclosure would also have to be marked with the words "Inside Package
)
Complies with Prescribed Specification" [see 49 CFR 173.25(a)] and also be labeled as required based on the dose rates at the surface and 3 ft from the outer enclosure.
4 CAUTION: The fact that a particular device has been issued an NRC certificate of compliance does not necessarily mean that, when fully loaded with its contents as authorized in a specific license, the dose rates will be within the regulatory i
limits.
Each package must be surveyec to assure that proper labeling is applied.
Packages exceeding the limits of 49 CFR 173.393(i) may be transported in a closed, exclusive-use vehicle, such as a radiographer's van, provided that the following limits are met:
1,000 mrem /hr at 3 ft from the external surface of the package, 200 mrem /hr at any point on the external surface of the vehicle, and 10 mrem / hour at 6 ft from the vehicle (49 CFR 173,393 (j)].
This means that a radiographer may transport a package reading more than 200 mrem /hr at the surface, but less than 1000 mrem /hr at 3 ft from the i
surface, in his own exclusive use vehicle.
The radiographer may not deliver t
the same package to a carrier for transport unless the carrier's vehicle is l
consigned for the radiographer's exclusive use.
i I
i
IN 81-02 January 23, 1981 Page 4 of 5 gipping Papers -- A shipping paper is required for each transfer of radio-active material from the confines of the licensee's plant, whether transported by the licensee or delivered to a carrier for transport.
The shipping paper must include the information required by 49 CFR 172.203(d) for radioactive material, including the following:
1.
The DOT proper shipping name. (For radiography devices, this will always be "RADI0 ACTIVE MATERIAL, SPECI AL FORM-N.O. 5").
2.
The name of each radionuclide.
3.
A description of the physical and chemical form of the material.
(For radiography sources this description is "SPECIAL FORM").
4.
The activity contained in each package measured in curies.
5.
The category of label applied to each package (RADI0 ACTIVE WHITE-I, RADI0 ACTIVE-YELLOW II, or RADIOACTIVE YELLOW-III).
6.
The transport index assigned to each pan: age bearing RADI0 ACTIVE YELLOW-II or RADI0 ACTIVE YELLOW-III labels.
7.
The package certificate identification, if it is an NRC-certified package.
8.
For shipments tendered to a common carrier, the appropriate signed shipper's certification, and, 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 or medical diagnosis or treatment must also be included [49 CFR 172.204(a), 172.204(c)(3), (4), and (d)].
NOTE:
Most radiography shipments would therefore not be authorized for passenger-aircraft shipments, since the intended use of the radio-graphy equipment is not for research or medical applications.
9.
Instructions for maintenance of exclusive-use shipment controls, in the case of packages transported with the higher dose rates allowed by 49 CFR 173.393(j).
NOTE:
The repetitive nature of radiography transportation lends itself to the preparation, of a " permanent" type of shipping paper documentation that is specific to each particular source / device configuration.
Such documentation could even take the form of laminated cards retained in the vehicle glove comp &rtment.
Vehicle Placarding -- The transport vehicle must be placarded by the licensec on the front, rear, and each side with the appropriate 00T placard (see 49 CFR 172.506 and 172.508) if any quantity of packages bearing the RADIO-ACTIVE-YELLOW III labels is to be carried in the vehicle.
For packages
.w-,-
IN 81-02 January 23, 1981 Page 5 of 5 tendered to a common motor carrier, the licensee must provide the required placards to the carrier at the time the packages are picked up.
NOTE:
DOT placard requirements should not be confused with radiography area posting requirements of 10 CFR 20.203 and 34.42.
SecuringCargoWithinVehicle--Radiographylicensees$hotransportdevices (packages) in their own vehicles must provide for adequate blocking, bracing, or tie-down of the package to prevent its shif ting or movement during normal transport.
Incidents frequently occur wherein devices are thrown off and lost from moving vehicles, often without the driver's awareness.
These incidents are usually caused by the failure to properly secure the devics, combined with a failure to secure the cargo door of the vehicle.
Recent cases of this type have resulted in civil penalty for failure to comply with 49 CFR 177.842(d).
I Recommended Action i
f Licensees should review all movements of radiography devices away from their i
place of storage to ensure that they are (1) using appropriate packages, I
(2) properly controlling radiation levels on packages shipped, (3) providing j
proper shipping documents, and (4) following the applicable carrier require-ments when transporting devices in their own vehicles.
No written response to this notice is required.
If you require additional information regarding this matter, contact the Fuel Facility and Materials l
Safety Branch of the appropriate Regional Office.
l l
Enclosures:
l 1.
Appendix A, 00T Specification 55 l
2.
Table I k
f i
l i
i f
. _,. _ _ _ _. -. _ _, _,.. - -.. _ -, ~ - _ - -... _ _. - _.. _. _. _. _ _. _. _
APPENDIX A DDT SPECIFICATION 55 3
I I78230 W 8'=d"=
888
- al =-
g 17s.:sms wc] dins d bsins.
emned. lead er sarenimum
- =ca, ahic3ded, endio cuve material. e tai When used to join parts of t.be tainer.
container must be perfo med in a work-g I;g =30_I ggg manlike manner and shall provide a noint e2dency of not less than 85 per-(ai Itequiredin andetans.
cent. The melting point of brazing sna-E 172.25b2 R=rwrc=emas for denign terial must be in excess of 1.000' F.
and coristmni I 148.250-4 Cossaces.
or NM mew deld to (a) Closure must be by positivt be mw in mnd steel or equally nre lastening dmee capable of withst=~'mr I
M severt 1:npacts without Iallurt.
(b) Lead c. *Jrs.nium metal sh3elding 3
3g,
,y ck fo,*
forming pat 1 of Closing device must be not more than 6 inches of lead or ura*
cc:npletely encased in m1ld steel or n!== tottal (see Note 1).
,;yg37 g,,,,,31,g,3g g3,g,3, C1 One-fou-'.h inch (%") th.tch for (c) Closure must be cf cc-set design tuore than 6 inches of lead or uranium where inserted into other parts of the tutta! (see Note 2 3 No73 2: menema of tend to be measured (d) A means must be provided on the tro=2 outar ecs, or source canty to nearnet closure to secommodate a seal of a type p at on outer contamer wat:-
that must be destroyed if container is eb) Lead or uranium metal shield to cpened for any purpose.
De ecmpletely encased so that melten
[ 178.050--$ Marking.
lead er uranlu= metal wi'.J not now away or Icae its sh!elding e.-'!cleney if involved (a) Marking on each containe* in an in a cre. The shaeld t ust be supported unobst ucted area. by embossing or die-2 the outer centatv-in such manner stampmg on the container, or on a metal that it cannot change postt.1on under any plate attached to the containct by weld.
ordinary conditions. Ps:ts o! the shteld IDE OT OT*EOl* In '*LLU' 'D0 DC'3T** *'
must be so des:rned that radiation can.
least %" In belght.as fo!!ows:
not be " beamed" at point where sections
!!) MT-U* ** (stars to be replaced le!.n to.' set destru requ! red).
ey the tare seicht of the container stor Ic8 Con:.ainers we:ghms more than example: DOT-55 250)). These marka 500 poundt must be Stted Mth sitids or thau ce caenstood to cert!!y that the container ec:nplies with all speciScation otbe vise designed so that excess 3ve o'c:ght w!11 be p*ereuted on M areas requirements.
of car or truck Soors.
(2) The worda "RADIOACTTVE (d) Containers setehine more than MA'I'EIAI'**
SDD pounds must be prorlded with boolts.
(3) Na:ne or ry=bol (letteral of hand!cs, st3ci. or other devices to f ac113 maker cr user assuming responsibility tate handling. '
for ec=pliance with speciacat:en re.
tel Containers must be of such sis, quirements; this toust be recorded with snt destg's as art necessar7 to reduce the Bureau of Explosivaa.
the radiation frem the ecutainer to w'.th!n the limits prescribed in i 173 233 of ths chapter.
~
(f) Centainers tenstructed with tub-tnr for cratnare purpose mur. have the.
cDening exterior to the shinntne con.
tainer plugged or capped. Dral lines must be plugrad or capped with a ma-teria2 which win have a melt-point at or below that of lead. for example, lead hard rubber,or plastic.
TABLE 1 RADIOGRAPHIC DEVICES HAVING NRC CERTIFICATES OF COMPLIANCE Manufacturer Name and Certificate Model Number Type Number Automation Industries 500 - SU Source changer 9006 520 Exposure device 9007 GAMMA Industries 6717-B Overpack 6717 20, 20A, 50, 50A Exposure device 9126 100, 100A, 200, 200A Exposure device 9127 C-8 Source cnarger 9128 St. Louis Testing Labs STL-201 Exposure device 9024 Source Product and Ecuipment Company C-1 Source cnanger 9036 SPEC 2-T Exposure device 9056 Magnaflux Corporation MX-1C-100 Exposure device 9110 Technical Operations 650 Source cnanger 9032 660, 660E Exposure device 9033 676, 676E Exposure device 9035 680, 680E Exposure device 9035 683 Overpack 9053 684, 684W Exposure device 9028 715 Overpack 9039 741, 741E Exposure device 9027 750 Source changer 9021 i
771 Source changer 9107 820 Source changer 9137 900 Exposure device 9141 I
~m v--
t IN 81-02 l
January 23, 1988 i
l RECENTLY ISSUED j
IE INFORMATION NOTICES Information Date of Notice No.
Subject Issue Issued to 80-45 Potential Failure of 12/17/80 All PWR facilities BWR Backup Manual Scram with an OL or CP j
Capability 80-44 Actuation of ECCS in the 12/16/80 All PWR facilities Recirculation Mode While with an OL or CP in Hot Shutdown J
80-43 Failures of the Continuous 12/5/80 All power reactor Water Level Monitor for facilities with OL the Scram Discharge Volume or CP at Dresden Unit No. 2 i
80-42 Effect of Radiation on 11/24/80 All power reactor Hydraulic Snubber Fluid facilities with OL or CP 80-41 Failure of Swing Check 11/10/80 All power reactor Valve in the Decay Heat facilities with an OL i
Removal System at Davis-or CP Besse Unit No. 1 80-40 Excessive Nitrogen Supply 11/10/80 All power reactor Pressure Actuates Safety-facilities with Relief Valve Operation to OL or CP Cause Reactor Depressur-ization 80-39 Malfunctions of Solenoid 10/31/80 All light water reactor l
Valves Manufactured By facilities with Valcor Engineering Corporation OLs or cps 80-38 Cracking in Charging Pump 10/30/80 All PWR facilities Casing Cladding with an OL or CP -
80-37 Containment Cooler Leaks 10/24/80 All power reactor and Reactor Cavity facilities with Flooding at Indian Point Ols or cps Unit 2 OL = Operating Licenses CP = Construction Permits
._ -.._... - _.. _ _.-._._. _, _ _.._, _.._. _.-._, -