ML20030D928
| ML20030D928 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20030D926 | List: |
| References | |
| FOIA-81-160 86740B, NUDOCS 8109170161 | |
| Download: ML20030D928 (21) | |
Text
{{#Wiki_filter:h, Transp;rtatien Activitics i Procedure No.: 867408 Issue Date: 4/1/80 l CONTENTS Page No. 'j I. Inspection Objectives I-l ] II. Inspection Requirements Program Review 1. Management Controls II-l Implementation 2. Selection of Packagings II-1 a. Procurement and Re-use 11-1 b. Special Considerations II-2 3. Preparation of Packages for Shipment l a. Filling and Loading II-3 b. Closing II-3 c. Liquid Packaging Provisions II-4 d. Package Marking II-4 e. Package Labelling II-5 f. Monitoring II-5 (1) Radiation limits 11-5 l (2) Contamination limits II-6 l (3) Heat limits II-6 i 1 l 4. Delivery of Completed Packages to Carriers II-6 l-a. Shipping Paper Documentation II-6 l b Loading of Packages on transport vehicles 11-7 5. Receipt of Packages II-7 \\ 6. Incident Reporting II-8 i ** 7. Intctrination and training program II-9 8. Licensee's Audit Program II-9 9. Examination of Packages II-10 10. Record Keeping 11-10 i '8109170161 810713 i PDR FOIA (AUDIN81-160 PDR
r-7 Transp rtation Activities Procedure No.: 867408 Issue Date: 471/80 Contents (Continued) Page No. III. Inspection Guidance 1. Management Contrnis, 111-1 2. Selection Packagings III-1 a. Procurement and re-use III-1 b. Special Considerations III-2 3. Preparation of Packages for Shipment III-4 a. Filling and loading III-4 b. Closing III-4 (4) Security Seals III-6 (5) Internal Bracing and Cushioning III-S c. Liquid Packagiag Provisions III-7 d. Packrige Marking III-7 e. Package Labelling III-7 f. Monitoring 'III-8 1. Radiation limits III-8 2. Contamination limits III-9 3. Heat limits III-9 4. Delivery of completed packages to carriers III-9 a. Shipping p;per documentation III-9 b. Loading of packages on transport vehicles III-10 5. Receipt of packages III-10 6. Incident reporting III-10 7. (blank) 8. Licensee's audit program III-10 9. Examination of packages III-11 10. Record keeping III-11 Appendix A - Copy of DOT Specification 55 A-1 Appendix B - IE Circular No. 78-03, " Packaging Greater than B-1 Type A Quantities of Low Specific Activity Radioactive Material For Transport" if
(...,,_ Transp rtatien Activitics Procedura No.: 867408 . Issue Date: 4/1/80 Contents (Continued) Page No. Appendix C - Overpacking of Radioactive Packages C-1 Appendix D - Interim IE Position on Exclusive Use, Open 0-1 Transport Vehicle Exposure Rate Limits s Appendix E - Description of " Chemical Form" on shipping papers. C-1 e 9 9 4 L iii
_Transr etatien Activitics Proc:du,o N3.: 867408 Issue Date: 4/1/80 SECTION I INSPECTION OBJECTIVES To verify that the licensee has established and implemented a management-controlled program for ensuring safety in the receipt, packaging, delivery to a carrier, and transport of licensed radioactive material, and to assure that the licensee is complying with NRC and certain POT regulatory requirements related to those sctivities. This procedure applies to the inspection of any licensed activity, e.g. reactor, fuel facility, or materials licensee, who engage in a transportation activity. NOTE: In fulfilling the inspe-tion requirements and objectives of this procedure, the inspector should assess the, adequacy of the various aspects of the licensee's program in view of the licensee's total l program; that is, consider for the various activities stated in the objective, the volume, curies quantities and types of radio-active material involved, the inherent potential radiological hazards, the complexity of the packaging required, the number of shipments made and received over a period of time, the number of licensee employees involved in the activities, etc. In other words, a " graded approach" should be used in assessing the adequacy of the licensee's program, with the smaller programs requiring complete but less complex and extensive controls than larger programs. In the same context, the extent and scopa of the inspection coverage may be adjusted accordingly. For example, i the inspection of a broad medical or academic program would i usually call for much more extensive coverage than for a typical I radiographer. In the former case, inspection of waste packaging would be of paramount importance, whereas for radiographers, inspection interests would generally involve the procurement, use, and transport of the devices. As another example, a large processor / supplier of medical isotopes would necessitate coverage of package procurement, prepa' ration, waste shipments, etc; as l contrasted to a small supplier of an item such as a smoke detector; l where the inspection coverage would be much more limited in its scope. l I e I-1
e i Transp:rtation Activitics 1 Procedure N;.: 86740B Issue Date: 4/1/80 SECTION II INSPECTION REQUIREMENTS Definition: As used in this procedure, the term " transport activities" means the processes of receipt, packaging, transfer, delivery to a carrier, and transport of radioactive materials. PROGRAM REVIEW 1. Management Controls. Identify the primary documents in which the system of management controls is documented (since this will vary widely among the licensees inspected under this procedure) and verify that the system of management controls includes: a. designation in w.-iting of the individual (s) and organization (s) assigned the responsibility for transport activities; and b. an explanation in writir.g of the authorities and duties of those individuals and organizations, including identification of the activities and processes for which they are responsible; c. written procedures or instructions for carrying out the various processes and details of the transport activities; i d. a documented program for indoctrination and training of personnel performing transport activities to assure that proficiency is achieved and maintained; l j e. a documented program of planned and periodic audits to verify l compliance with requirements and determine the effectiveness of l the controls over transport activities. f. a documented program for quality assurance, if required b,v in CFR 71.12 and 71.51, incorporating the criteria of 10 CFR 71, Appendix E, and l approved for use in Accordabce with 10 CFR 71 prior to January 1,1979. l-IMPLEMENTATION l 2. Selection of Packagings. i a. Procuremant and re-use: For packaging that has been procured / fabricated and used to transport radioactive materials: j (1) review records of the licensee's determination that new packagings have been fabricated in accordance with the approved design; i.e., design as specified in an NRC Certificate, a 00T Specification, or IAEA Certificate; II-1 1 L_
s 1 Transportation Activities 1 I Eroc:: dure No.: 86740B I:; sue Date: 4/1/80 l l (2) examine available fabricated packagings for conformance with l the approval criteria, including DOT Specification markings or Certificate markings required; (3) review records and examine used packagings to determine whether the licensee's procedures for re-use of packagings are satisfac-tory to assure compliance with the requirements; 173.22(a), 1 173.393(n),71.54 (4) verify that, for Type B and fissile radioactive materials, the licensee has a copy of the NRC Certificate of Compliance and the documents referenced in the certificate; 173.393(a)(1), '/1.12(b)(1)(i) (5) verify that, for Type B and fissile radioactive materials transported in foreign-made packagings, the licensee has a copy of the IAEA Certificate issued by DOT, and the documents l referenced in the certificate; 71.12(c)(1) l (6) verify that each package design has a minimum outside dimension of four inches; 173.393(c) (7) confirm that for NRC-certified packages, that prior to initial use the licensee has submitted in writing to NMSS, his name, license number, NRC packaging certificate number, and the package identification number. 173.393a(1), 71.12(b)(1)(iii) b. Special considerations. (1) DOT Spec 7A: For any Type A package design which is marked and used as a D0T Spec. 7A, ascertain that the licensee, in accordance with written procedures, maintains on file (for at least one year after each shipment) and is prepared to provide a copy of, the certification and supporting safety analysis demonstrating that the construction methods, package design, and materials of construction are in compliance with the specification. 173.394(a)(1), 173.395(a)(1) (2) 00T Spec 55: For a DOT Spec. 55 package design, ascertain that the licensee does not offer for transportation any such package manufactured after March 31, 1975. 173.394(a)(2),173.395(a)(2) (3) Special Form: For a package of exempt (limited quantity) or Type A material, in which the shipper relies on a special form determination in order to qualify the package for the exempt or Type A category; ascertain that the licensee maintains on file for at least one year after the last shipment, a certification and supporting safety analysis demonstrating that the special form material meets the test requirements of the regulations. 173.398(a), Notes 1, 2 II-2 l
Transp:rtation Activitics Procedure Ns.: 867400 ~ Issue Date: 471/80_ \\ (4) Plutonium shipments by air: Ascertain that the licensee does i not offer plutonium shipments by air, other than in a PAT-1 i package, or as a medical device implanted in a human, j 175.10(a)(8); and Public Law 94-79, August 9, 1975. (5) Exempt (Limited Quantities or Devices): Ascertain whether in such cases that the licensee prepares and offers for transpor-i tation any packages of exempt (limited) quantities or devices, that he is correctly applying the regulatory limits on the quantity, form, and radiation. 173.391(a)-(c). (6) Full Load Shipments of LSA: Ascertain whether in the case of LSA shipments, the licensee takes into consideration the distinct differences in the requirements for packaging, marking, and shipment of such materials when offered for transportation as l full loads, as contrasted to w full-loads. 173.392(a)-(d). l l 3. Preparation of Packages f9r Shipment a, Fijling and Loading (1) Ascertain that prior to first use, the licensee has, in accordance with written procedures: assured that the packaging meets the specified quantity of design and construction; 173.393(m)(1),71.53 verified the effectiveness of the shielding and containment and, where necessary, that the heat transfer characteristics of the package are within the limits applicable to or specified for the package design. 173.393(m)(2),71.53 (2) Ascertain that prior to each use, the licansne, in accordance with written procedures, assures that: the packaging is proper for the contents to be shipped; 173.393(n)(1) 71.54 the packaging is in unimpaired physical conditions, except l. for superficial marks; 173.393(n)(2),71.54 any special instructions for filling the package have been followed including, for fissile materials, the insertion i of any required moderators or neutron absorbers. 1 173.393(n)(5),71.b4 b. Closing. Ascertain that the licensee, in accortfance with written " procedures, assures that: II-3 ,y4- ,,7
Transportation Activities Procedure N).: 867408 Issue Date: 4/1/80 (1) each closure device of the package, including any required gasket, is prope ly installed and secured and free of defects' 173.393(n)(3). t (2) each closure, valve, or other opening of the containment system l is properly sealed; 173.393(n)(5) (3) any special instructions for closing the package have been l followed;. 173.393(n)(5) (4) the outside of the package incorporates a security seal which, l when intact, provides evidence that the package has not been l illicitly opened; 173.393(b) (not required for exempt or LSA packages) (5) any internal bracing or cushioning materials are in their proper place. 173.393(d)(1) c. Liquid Packaging Provisions. Ascertain that the licensee, in accordance with written pT6cedures, assures that for NON-LSA liquid-containing packages: (1) contents are contained with a leak-resistent, corrosion-resistant inner containment vessel; 173.393(g) (2) the package is adequate to withstand a 30-foot ' cop test without l loss of contents from the inner-containment veuel; 173.393(g)(1) i l (3) absorbent material is used in a quantity sufficient to absorb at l least twice the volume of liquid contents in the event of leakage 173.393(g)(2); or l (4) a double-containment system is used, 173.393(g)(3); (5) and for those packages destined for air shipment and containing liquids in excess of a Type A quantity, that, a l test for leakage is performed on the containment system. 173.393(n)(7) d. Package Marking. Ascertain that the licensee, in accordance with written procedures, assures that a package: (1) is marked with the proper DOT shipping name; 172.300, 172.101 j (2) exceeding 110 pounds (50 kg) gross weight is plainly and durably marked with such weight on its exterior; 172.310(a) (3) conforming to the requirements of either a Type A or Type 8 package is plainly and durably marked as such; 172.310(a)(2) 1 II-4
~ _.., Transpartatien Activitics Procedura N;.: 86740B Issue Date: 4/1/80 (4) shipped under an NRC or DOT Certificate, or DOT Specification, is properly marked with the Certificate or Specification identification; 173.24(c)(1),173.393a(a)(2),173.393b(a)(2) (5) in which the DOT specification package is further enclosed within a non-specification outer overpack or enclosure, is marked on the exterior with the proper DOT shipping name and the additional marking that the "Inside Package Complies with Prescribed Specification"; 173.25(a) (6) of 'iow specific activity radioactive materials shipped as f'.ril-load is marked, " Radioactive-LSA; 173.392(c)(8) (7) is marked with the name and addrass of the consignee or consignor; 172.306 (not requirto for LSA packages, exempt packages, or packages shipped as full-loads) (8) when marked, is marked in accordance with the physical marking requirements of 172.304. e. Package Labelling. Ascertain that the licensee, in accordance with l written procedures, assures that a package: i l (1) having contents with more than one hazardous materials I classification characteristic in addition to radioactivity is labelled as required for each class; 172.402,172.403(e) l (2) requiring "RADI0 ACTIVE" labels, has two appropriate labels affixed, one each on opposite sides of the package; 172.403(f) (3) requiring either a Radioactive White-I, Yellow-II, or Yellow-III label, is labelled as appropriate based on the surface and 3-foot dose-rate limits and other regulatory criteria; 172.403(a) through (d) (4) requiring eitber of those labels has the apnropriate items of information entered on the blank spaces in accordance with the regulatory criteria. 172.403(g) l f. Monitoring (1) Radiation Limits: Ascertain that the licensee, in accordance with written procedures, assures that a package complies with i the radiation level limits at the surface of the package and at three feet (transport index), and that such limits are l used to determine the appropriate package label to be applied 173.393(i), 173.393(n)(3) II-5 s l
.l ~ Transportation Activitin Proc: dure No.: 86740B Issue Date: 4/1/80 (2) Contamination Limits: Ascertain that the licensee, in accordance with written procedures, controls and removable non-fixed contam-ination on a package below the regulatory limits. 173.393(n)(9), 173.397 (3) Heat Limits: Ascertain that the licensee, in accordance with written procedures, controls the design, construction, and loading of the package so that any heat generated within the package due to the radioactive contents does not at any time during transportation affect the efficiency of the package or cause the surface temperature to exceed the specified limits for packages shipped as either full-load or non full-load; 173.393(e) 3. Delivery of Completed Packages to Carriers a. Shipping Paper Documentation: Verify that the licensee, in accordance with written procedures, prepares (172.200(a)) appropriate shipping papers, which include the folicwing items of inrormation, as applicable: (1) D0T proper shipping nr.me; 172.202(a)(1), 172.101 (2) Class of the Hazardous Material; 172.202(a)(2), 172.101 (3) The name of each radionuclide. 172.203(d)(1) (4) A description of the physical and chemical form. 172.203(d)(ii) (5) The activity contained in each package. 172.203(d)(iii) (6) The category of label applied to each package. 172.203(d)(iv) (7) The transport index assigned to each package. 172.203(d)(v) (8) The words " Fissile Exempt" or other notations if applicable; 172.203(d)(vi) (9) The package certificate identification, if it is a DOE or NRC-certified package (172.203(d)(vii) 173.393(a) (10) The package certificate identification. if it is a foreign-made package certified by DOT pursuant a IAEA requirements. (173.393b) (11) For foreign-made Type A or LSA packages, the appropriate notation as required. 172.203(d)(ix),171.12(e) II-6
v Transportation Activitics Procedure No.: 867408 Issue Date: 4/1/80 (12) The appropriate signed, shipper's cgrtification, and for shipments by aircraft, the additional stateme'nt as to acceptability for either passenger-carrying or cargo-only aircraft. For shipments by passenger-carrying aircraf t, the additional statement of intended use in research or medical diagnosis or treatment must also be included. 172.204(a),172.204(c)(3),(4),(d) (13) Instructions for maintenance of sole-use (exclusive-use) ship-ment controls, when applicable; i.e., full loads of LSA materials, shipments with higher radiation levels, and Fis;ile Class III shipments. 172.392(c)(9), 173.393(j), and 173.396(g)(1) b. Loading of Packages on Transport Vehicles. (1) Non-Full Loads: Verify that the licensee, in accordance with written procedures, prevides the highway carrier with the required placards or affixes to the rail car and required packages at the time that packages of radioactive materials bearing the Radioactive-Yellow III labels are offered for transportation (unless the carrier vehicle is already placarded as required). 172.506, 172.508 (2) Full Loads (also referred to as Sole-Use or Exclusive-Use): Verify that the licensee, in accordance with written procedures: assures that the radiation levels are within the required limits; 173.393(j) placards the transport versicle, as required, when trans-porting full loads of low specific activity radicaxtive materials, except for shipments of unconcentre.ted uranium or thorium ores; 173.392(c)(7) verifies that the removable surface contamination on packages does not exceed 10 times the levels allowed for packages consigned for non sole-use. 173.397(b) Blocks and braces the shipment within/on the transport vehicle in such a manner so as to prevent leakage or 1 shift of loading under conditions normally incident to transportation. c. Notification of Consignee: Verify that the licensee, in accordance with written procedures, notifies the consignee prior to shipment of the dates of shipment and expected arrival and any special loading / unloading instructions when Type B and/or fissile materials are involved. 173.22(b), 71.55 Receipt of Packages. Ascertain that the licensee, in accordance with written procedures provides for: II-7
Transportrtion Activitics Procedure No.: 86740B Issue Date: 4/1/80 a. Safely opening received packages of radioactive material. 20.205(d) b. Prompt receipt of packages containing more than a Type A quantity of radioactive material. 20.205(a) c. Expeditious pickup of a package containing more than a Type A quantity of radioactive material from a carrier terminal after receiving notification from the carrier of the arrival of the package at the time of arrivul, d. Monitoring of packages for external radioactive contamination as soon as practicable after receipt, but not later than 3 hours after receipt during normal working hours or 18 hours at other times. 20.205(b) Exempted from this monitoring requirement, are packages containing: not more than 0.01 mci of Group 1; 0.1 mci of Group II; 1 mci of Groups III, IV, V, VI, and Special Form; 25,000 mci of Group VII, and 10 mci of H-3, C-14, S-35, or I-125. only radioactive material as gases or special form. non-liquid radioactive material and not more than a Type A quantity. no more than 100 mci of radioactive material with half-lives of less than 30 days. e. Immediate notification of the delivering carrier and the NRC Regional Office when removable contamination exceeds 0.01 microcuries (20,000 dpm) per 100 square centimeters. The NRC Regional Office is to be notified by telephone and written telecommunication. 20.205(c)(2) f. Moaitoring of the radiation levels of packages containing radioactive material in excess of Type A quantities, other than those shipped by exclusive use vehicle. Such monitoring shall be done as soon as practicable, but not later than.3 hours after receipt during normal working hours or 18 h at other times. 20.205(c)(1) g. Immediate notification of the delivering carrier and the NRC Regional Office if the radiation levels exceed 200 mr/hr on the surface or 10 mr/hr at three feet. Notifications are to be made by telephone and written telecommunication. 20.205(c)(2) 6. Incident Reporting a. Ascertain that the licensee (when acting also as a private carrier) reports, in accordance with written procedures, any incident that 7 l 11-8
3n Trar.sportation Activities Frecedure No.: 867408 Issue Date: 4/1/80 occurs during the course of transporting radioactive materials, 'in which as a direct result of the radioactive materials: 171.15, 171.'16 ~ l: .a p'erson is killed, a person receives injuries requiring his hospitalization, estimated carrier or other property damage exceeds $50,000, fire, breakage, spillage, or suspected radioactive contamination occurs. b. Ascertain: (1) Whether or not there were any instances where the effectiveness t the packaging was substantially reduced during use. (2) That instances of substantial reduction were reported to Mi5S within 30 days of the instances. 71.61 7. Indoctrination and Training Program Verify implementation of the indoctrination and training program for people involved in the licensee's transport activities: a. discuss the program with the licensee's representative charged with the responsibility for the training--identify the major element of the program: the basis used for selection of personnel to be trained; l schedules and performance of training; and methods used to assure qualification and competence and to keep people informed of changes-in procedures and requirements. b. examine records of training completion for 10% (or, no fewer + San 1 or more than 5) of employees involved in transport activities. c. discuss the training with 1 or 2 supervisors and 1 to 5 employees, selected at random, to (1). verify their participation in the training program, and (2) check their degree of knowledge of 3 to 5 specific ) requirements selected from procedural sections 2 through 5 above, 4 and (3) check their degree of knowledge of the licensee's specific procedural requirements. 8. Licensee's Audit Program a. Review the repcrt of the most recent audit of transport activities conducted by the licensee and verify that: 3 (1) it was apparently conducted in accordance with the licensee's published procedures, and II-9 w
.n Transportation Activicies Precedure No.: 86740B Issue Date: 4/1/80 (2) identified deficiencies (if any) were corrected, or are being corrected, prior to any more shipments being made, b. Discuss tne audit program with 1 to 5 employees, celected at random, to check their degree of knowledge of the program and to aid in assuring that the licensee is conducted an adequate program. ~ 9. Examination of Packages Jf possible, select a package of radioactive waste that has been completely prepared (including final quality control) and is awaiting shipment and f rcstruct the licensee to open it. For those packages selected: a. condect a limited spot-check of container contents against records, , mark'r.g or laoeling for the container; b. ' verify the absence of free-standing liquid in the package; c. a)certain that the packaging is proper for the cantents; 3 d. verift that the packaging is in unimpaired pnysical condition, except for superficial marks. J 10. Record keeping: 71.62 7. Ruview the records system to verify thati a. The licensee mair.tains for a period of two years records of shipments of fissile material of or more than a type A quantity of radioactive material in a single package-b. The record for such shipment conteins the following:
- 1) The packaging model number ii) Significant defects in the pachaging and means to repair the defects iii) Volume of coolant iv) Type of quantity of material in each package and in each shipment v) For irradiated fissile material, the model number of the item; and irradiation and decay history (to show nuclear and thermal characteristics comply with license); and abnormal radiation _ safety condit;ons iv) Date of shipment vii) Fissiles Class III controls 11-10
Transportatien Activities Procedure No.: 86740B Issue Date: 4/1/89 viii) Name and address of transferee ix) Address to which shipment made x) Results of the licensee determinations in Item 2 above; c. The licensee did not ship plutonium, other than that in a medical device designed for individual application, by air transport; and d. After June 17, 1978, the licensee shipped plutonium in excess of 20 curies only in solid form in double containment packages specifically approved by NMSS. 71.42 s a II-11
r Transportation Activities Procedure No.: 86740B Issue Date: 4/1/80 SECTION III INSPECTION GUIDANCE Note: Discussion and Guidance which follows corresponds to the applicable paragraph numbers as contained in Section II - Inspection requirements Regulatory references cited are against 49 CFR Parts 170-178 or 10 CFR 71. PROGRAM REVIEW 1. Management Controls The inspection effort should be directed at verifying that written pro-cedures have been established in a manner approved by management. The procedures should be readily available to all those having responsibility for an" phase of the licensee's transportation activity. The inspector should confirm that the procedures include provisions for all of the applicable transport activities addressed in Section II. In reviewing the adequacy of the licensee's program for management controls and associated written documentation thereof, inspectors are reminded to concurrently review, as a cross-check, the licensee's written, apprcved Quality Assurance program which incorrerates the elements of 10 CFR 71 Appendix E. The requirements of this procedure are specifically designed so as to assure that such a review will take place as a natural course of events. 2. Selection of Packagings a. Procurement and re-use
- t The inspection efforts listed in this section are intended to verify the adecuacy of the licensee's program for selection, procurement fabrication, and reuse of appropriate packagings to be used for shipping radioactive materials.
For Type B, fissile a,nd certain Type A packages designs certified by NRC, a necessary reference is NUREG-0383, " Directory of Certificates of Compliance for Radio-active Materiale packages," which is issued and updated annually by NMSS. DOT Specification Packaging designs are published and listed in 49 CFR Part 178, except for the DOT Spec. 55 (See Attachment A). Authorizations for content Limitations in DOT Spec. Packagings are found in 49 CFR Parts 173.394, 173.395, and 173.396. Inspectors are reminded of the differing requirements of 49 CFR and 10 CFR 71 for packages of LSA when shipped as full-load. IE Circular 78-03, May 12, 1978 " Packaging Greater Than Type A Quantities of Low Specific Activity Radioactive Material for Transport" is attached as Appendix B for further guidance. Ill-1
A Transportation Activities Procedure No.: 867408 Issue Date: 4/1/80 1 b. 'Special considerations (1) 00T Spec. 7A (178.350) - In 1975, DOT amended its regulations { .for Type A packages so as to delete all references to use of' t' previously listed DOT Spec. drums, boxes,.etc. as authorized Type A packages. In their place, complete reference was made 3 to use of the DOT Spec. 7A " performance" standard package only, except for the DOT Spec. 55 (which was stated to be in the process of being " phased out"). Associated with this change was the imposition of a new requirement that each shipper of a Spec 7A package must document and maintain on file for at least one year after the latest shipment, a written report.of his determination (safety analysis) of-how his package complies 4. with the Specification 7A test requirements. Inspectors should verify that this' documentation safisfactorily address how the package meets the requirements of 173.398(b) and what the rr a ts of the applicable tests were. It is not necessary that tw shipper have done the test or analysis himself,.only that he have the record in his possession. In this regard inspec-l tors may find some shippers furnishing and relying on test i results and data extracted from a technical report by the former ERDA, entitled " Certification of ERDA Contractors-Packaging With Respect'to 00T Specification 7A performance j Retuirements," Report MLM-2228 June 12, 1975 with one Supplement, j April 15,1976. A. question may!then arise as to the sufficiency l-of the test data from this report in any given case. Judgement l will then have to be excercised in assessing whether the licensee's specific package falls within the parameters of the tests as l reported in MLM-2228, with respect to such aspects as maximum l package weight tested type of closure, and content limitations. The Licensee's documentation should include a rationalization l concluding how the package meets the Spec. 7A test requirements based on the MLM-2228 data, or any other independent package i tests which have been performed. In any, case, inspectors should reject any rationale used by the licensee that the marking alone-of DOT Spec 7A on the outside of the package is sufficient fu1F fillment of this requirement. i (2) DOT Spec. 55'- In 1975 the D0T began the regulatory " phase-out" of the DOT Spec. 55 as an autho'rized package for specified quantities of special form Type B materials (up to 300 C1). ) ~ j' As of March 31, 1975, shipments in Spec 55 packagings constructed after that date have no longer been authorized. In a more j recent Notice of proposed rulemaking (Docket HM-169, January 8, i 1979), DOT has proposed the complete phase-out of DOT Spec 55; in that o ipments in any Spec. 55 would no longer be authorized [ one year after the date of any final amendment adopted. Future use of any Spec. 55 designs would then be contingent upon the j s, hipper applying for and receiving an NRC Certificate of j III-2 i t i + - - yw+ ,-s.,-'- ..r- ,y y ~.,[ ,.7.,m.m.,,-.,- .,_,w,,m,m.,, y..,...,c,.,,r[..w,_,%,y.,g,.w.,yg y
Transportation Activities Procedure No.: 867408 Issue Date: 4/1/80 Compliance for the package. For any Spec. 55 pack tes noted to be in use by licensees, inspector's should atte g to ascertain the date of construction, if possible. Since the DOT no longer publishes the Specification itself in 49 CFR 178, a copy of the Specification from an earlier 00T Title 49 is included as Appendix A hereto. Many old radiography devices and " lead pigs" currently in use were presumably constructed as DOT-Spec. 55. Several important rules of thumb should be kept in mind. Spec. 55 packages, properly marked, may be used for transport of up to 300 Ci of special form material (see 173.394(b)(1). For Type B quantities exceeding 300 Ci, an approved Type B package could consist of a Spec. 55 within an outer wooden protective over coat. (See 173.394(b)(5) and (6) for the Spec. 20 WC' and 21WC; 178.194 and 178.195) (3) Special Form - As of December 31, 1975, DOT has required that each shipper of special form radioactive material must maintain on file for at least one yea after the latest shipment a certification that the special form material meetc the test requirements (173.398(a)(4), note 1) The actual testing need not have been performed by the shipper, however, the certificate must address the results of the tests and other information listed in 173.398(a)(4), Note 2, or 10 CFR 71, Appendix D. The NRC Director of Sealed Sources may be a useful reference resource in some cases. Reliance by the shipper on a special form determination may be very important for Transport Groups I-III in establishing whether an exempt or Type A; Type A or Type B quantity / package is required, i.e., .01 mci of Pu-239 in non-special form is an exempt quantity whereas up to 1 mci of the fame' material in special form would be an exempt quantity and 50 mci of Sr-90 in nt1-special form is Type A, whereas up to 20 Ci of the same material in special form would be the limit for Type A. (4) Plutonium Shipments by Air - Except for shipments in the PAT-1 package (NRC Certificate 0361), NRC Licensees may not offer for-transport by air any plutonium. An exception of this restric-tion would be the transport of any radioactive material by air in the form of an implanted medical device (e.g., " pacemakers") or as injected or ingested radiopharmaceuticals. (See 49 CFR 175.10(a)(8)) (5) Exempt (Limited Quantities) and Devices - Licensee procedures for packaging and transport of limited quantities or exempt devices pursuant to 49 CFR 173.391 should be examined if appli-cable. Inspectors should verify 'whether the licensee is correctly III-3 I
Transportation Activities Procedure No.: 867408 Issue Date: 4/1/80 applying the quantity and form limits for such materials. Shipper-of such materials are also responsible for the preparation of shipping papers. For U.S. Postal Shipments, the applicable requirements for licensees are found in U.S. Postal Service Publication No. 6, 1975 which states essentially that any radioactive material package that requires a Label is non-mailable, i.e., the quantity limits and requirements of 173.391 must be met in order that a radioactive material be offered for postal shipment. With regard to the 173.391 limits, inspector's should ensure that a clear distinction is made between the material " schedule" limits of 173.391(a) vs. the " device" limits of 173.391(b). Clearly, the regulations allow more activity as an exempt package when in the form of " devices," rather than as the " scheduled" quantities. (6) For shipments of LSA packages in other than " full-loads" (see 173.392(a)), packages must be marked and labelled as required, and must essentially be Type A packages, except that relief is given from some of the general packaging requirements (173.392(a)-(e) and (g)). However, when such LSA materials are t~.ansported as full-loads, only " strong-tight" packages are required, and the packages are exempt from labelling, with the marking "RADI0 ACTIVE-LSA" required. Certain other requirements of 173.392(c) are also prescribed, Appendix B details the Nit, requirements (which differ from those in DOT regulations) for LSA packages when the activity in the package exceeds a Type A quantity. NRC Certificates of Compliance are issued for such packages, and usually prescribe " full-load" shipments as a requirement. 3. Preparation of Packages for Shiptrent a. Filling and Loading b. Closing These inspection steps are among the most impo, tant. The inspector should carefully observe licensee procedures to see that written procedures are followed in preparing tne package for use, in loading its contents, and in its closing. In reviewing the licensee's procedures, or to initial use of packagings; th,e requirements of 10 CFR 71.53 and 49 CrR 173.393(m) are applicable. Additional guidance follows: III-4
t. Transpartation Activities Procedure No.: 867408 Issue Date: 4/1/80 Defects include but are not limitt d to voids, cracks and pinholes. To significantly reduce the effectiveness of the packaging, the l defect must be such as to affect the cont;;inment of the licensed material or coolant or shielding material or to permit inleakage of l L material in the transport environment, e.g., water. 'For packages which will have maximum normal operating pressures ;i. excess of 5 pounds per square inch gage, the licensee must test each containment vessel at a pressure which is 50% above the maximum l normal operating pressure. The acceptance criteria for the test is usually contained in the application. If the acceptance criteria is not in the application, the licensee must establish such criteria in his test procedure. The model number is specified on the Certificate of Compliance. Note that 71.53(c) requires the licensee to determine that the package has been ~abricated in accordance with the design approved i by the Commission. The licensee may not purchase packaging with the l model applied unless the determination has been made by the licensee or the licensee agent while the packaging is at the vendor shop. The procedures should provide ~ criteria for identifying unacceptable defects. Defects will depend on the type of packaging and on the radioactive material contents. The containment leak test will normally be required for casks using liquid or gasecus coolant and l for casks shipping gases such as tritium. Specific procedures j should be available for each type of packing to ensure that components important to safety are included in the determination that the packaging has been fabricated in accordance with approved design. A record should be established for each reusable packaging. Because many packagings are procured in lots and without serial numbers, the reccrd may exist for a large quantity ( packagings specified as in a purchase order. Special emphasis saould be placed on records which -50w that components important to safety have been inspected for conformance to NRC-approved design. Depending on the type of package, this may include structural, thermal, shielding, containment, closure, and criticality - control systems. The records may include visual observations and physical test results. The packages should have the configuration and components described in the NRC-approved design or in the 00T speciation. Note that a container is not considered to be a package until the licensee has l determined that fabrication is in accordance with approved design and has authorized the marking of the container with the model number. The model number need not be applied until radioactive material is to be loaded into the packaging for the purpose of transporting' the material outside the licensee's place of use. III-5 -9 4 yr
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Transportation Activitir:s Procedure No.: 867408 Issue Date: 4/1/80-The records must be maintained for the life of the packaging. The records need not be at the place of use, but must be made available to the inspector. The licensee must notify NMSS of his ' intent to use an NRC certificated package prior to his initial use. The licensee does not need approval from NMSS as long as the certificate authorizes use under 71.12(b) of the general license. Note - Some of these requirements may have been completed by the Vendor Inspection Branch pursuant to Procedure No. 86718B during cask fabrication inspections. In such instances, reinspection is not necessary. Note - Even when an approved design is being utilized, if it is not in its proper condition as required by the design approval, safety may be adversely affected. A relevant requirement in 49 CFR 173.22 reads in part, as follows: "...the shipper shall be responsible to determine that shipments of hazardous materials are made in containers which...have been made, assembled with all their parts or fiu.ings in their proper place, and marked in accordance with applicable specification". (b)(4) Security Seals With respect the requirements for a security seal on packages, much confusion exists as to how this performance requirement can best be fulfilled. On some types of packages, e.g., steel drums, hinged-lid boxes, etc. provision for a seal consisting of a serially numbered lead-wire with a " logo" imprint is fairly straight forward and effec-tive. On other designs however, such as fiberboard cartons, it is not so simple - much more ingenuity is often needed to design an approrpriate seal. Pressure-sensitive tape applied to the box seam closure can be effective, if such tape, upon being removed clearly results in tearing away of the carton's outer skin surface such that any replacement of the tape would mi.ke it clearly obvious'that the box had been opened previously. Inspectors are further reminded that exempt (limited) quantity or exempt devices, as well'as LSA packages as either full-~ load or less-than-full-load shipments are not r equired to have a security seal. (b)(5) Internal Bracing and Cushioning. This requirement is especially important when examining the adequacy of any licensee's packages used for medical radiopharmaceuticals. In some cases poor designs allow for loose movement of inner contain-ment vessels within the outer fiberboard cartons, thus increasing the potential for a breached or damaged package. III-6
Transportation Activities Procedure No.: 867408 Issue Date: 4/1/80 c. Liquid Packaging Provisons. These requirements also are very important in examining licensees' medical radioisotope packages. Inspectors should inquire as to the test results of the 30' drop test on the package prototypes and also examinate the packaging configuration of the inner containment vessel to assure that the positioning of the absorbent used is such that liquid would in fact make contact with the absorbent in the event of leakage. Inspectors are reminded that-the liquid packaging requirements of 173.393(g) do not apply to LSA packages or to NRC certified packages (since each NRC certified package is individually reviewed and approved with respect to its containment system and contents). With respect to type B packages of liquids destined for air shipment, the shipper must perform an actual leakage te,t on each package exceeding a type A quantity before it is offered for transpc-tation. Acceptable leakage test methods are described in Regulatory Guide 7.4 (ANSI Standard 14.5). d. Package Marking. The various requirements for package marxing are found in several different sections of 40 CFR. They comprise a very important aspect of the overall regulatory scheme for identifying radioactive materials shipments. Marking deficiencies may often be symptomatic of more serious deficiencies in packaging. Inspectors are reminded that LSA packages transported as full-load must be marked " Radioactive - LSA" in lieu of any label. Frequently questions arise when in a full load consignment, packages are marked and also labelled, often indicating higher Transport Indexes than would be allowed in a non full-load shipment. Such labelling is redundant, with the existence of such higher radiation levels being~ allowable under 173. M3(j). Physical requirements for the legibility and location of the marking requirement itself are found in 172.304, e. Package Labelling Inspectors should be aware that altt;ough the proper Category of label is based principally on the level of radiation on the package surface and at 3 feet (tri.nsport index). Tha!. there are several i exceptions listed in 172.403(g). These exceptions involve cert'ain restrictions on label category based on the Fissile Class, if fissile materials are involved, plus the mandatory use of a category III label for fissile Class III packages. In the case of fissile Class II shipments, inspectors are also reminded that the transport index assigned to the package label may be assigned on the basis of either nuclear safety or radiation, whichever number is higher. What this means is that iii inspecting and surveying a package with a recorded III-7 s r
Transpartation Activities Prncedurm No.: 867408 Issue Date: 4/1/80 l Transport Index, a radiation level at 3 feet from a Fissile Class II . package may not be consistent *<ith the recorded T.I on the label. This is not a violation if the TI had been assigned on the basis of the nuclear safety value. Inspectors are also reminded that LSA packages in other-than-full loads are required to be labelled whereas as full loads, they only are required to be marked " radioactive-LSA." f. Monitoring. (1) Radiation Limits - Licensees who package and offer for 4 transportation large numbers of small medical radiopharmaceuticals often use an " assembly-line" process, in which the loaded package travels past a fixed, pre-set radiation detector. Inspectors should carefully examine such systems to assure that they in fact are effective in assuring compliance with the regulatory limits for radiation levels. Another question which frequently arises is the placement of a specification package, e.g., such as a radiography projector within an outer box or other type whether or no,during transportation. The. question involves of enclosure t the radiation levels at the surface of the outer box and at 3 feet from the outer box may be used to establish the label requirements for the overall package. Since D0T regulations do not address this, it is therefore permissive. Assuming that the inner package (the device) is labelled and marked as a specification package, the outer enclosure wi ld however, need to be further marked with the words "Inride Packaging Com% ;es with Prescribed Specification" (See 49 CFR 173. ?5), and labelled as required based on the radiation levels on tne outer enclosure. Frequently, multiples of small radioisotope carton-type packages are combined into plastic bag or fiberboard carton outer enclosures. The 00T regulations are essentially silent on specific requirements for labelling, marking, and transport index determinations on such over packs. As guidance in these instances, inspectors should refer to the copy of a DOT /0HM Newsletter article, issued in December 1974, exhibited as Appendix C. The provisions therein are currently under consideration by DOT in a Notice of Proposed i Rulemaking, issued in 1977 (Docket HM-152, Notice No. 77-6, 42 F.R. 37427, July 21, 1977) With r'egard to the higher radiation levels for a sole-use vehicle, pursuant to 49 CFR 183.393(j), there is presently some ambiguity as to whether the higher levels authorized for the package T.I. and the Vehicle surface (See 173.393(j)(14(2)) are authorized in the case of an open sole-use vehicle. Clearly III-8 1
I i Transportation Activities 1 Procedure No.: 86740B Issue Date: 4'/1/80 j the 10 mr/hr at six feet limit in 173.393(j)(3) ap;, lies to both open and closed vehicles. The bracketed "(Closed transport vehicle)" which appears in 173.393(j)(1)&(2) would suggest l strongly that in the case of an open transport vehicle, the j lower package radiation limits of 173.393(i) apply, with a limit of 10 mr at 6 ft. from the planes of the surface of the i vehicle allowed. The DOT has been formally questioned on the i correct interpretation of this regulation. The interim NRC/IE position on this matter is described in Appendix D. (2) Contamination Limits The allowable removable surface contaminati'on for packages transported as full load vehicles is ten times that allowed for i those in non full-load vehicles (See 173.397(c)). There is an added requirement, imposed on the carrier, that vehicles used for such shipments niust be surveyed for radiation and contamination after use. This requirement is normally not performed by the carrier, but rather by the consignee. Clearly, however, the basic responsibility for assuring that it is performed rests with the carrier regardless of who actually performs it. Inspectors should thersfore refer cases of violation of this requirement to DOT, except in the case of licensee / shippers who also act as private carriers. In monitoring and surveying for rerovable surface contamination, established health physics techniques should be followed. j (31 Heat Limits In some cases, e.g., large casks containing spent fuel, compliance with tne heat limits for packages shipped as full-loads is achieved by the installation of temporary, "see-through" barriers, screens, cages, etc about the cask, these barriers i are intended to prevent direct contact with the thermally hot cask surface. In such cases it is permissable for the 180 F surface temperature limit tj be applied at the surface of the temporary barrier rather than the cask surface. (4) Delivery of completed packages to carriers. (a) Shipping Paper Documentation - Requirements for shipping paper discriptions constitute a very important leg of the " triad" of hazardous materials regulatory "cornunications" requirenents, the others being labels / marking, and vehicle placards. Generally speaking, as is the case for marking, obse"vation of shipping paper deficiencies may be symptomatic c: nore serious deficiencies in packaging, therefore in'.,pectors should be familiar with the detailed shipping s III-9
i Transportation Activities Procedure No.: 867408 Issue Date: 4/1/80 P paper requirements. The requirements for entering informatior on the " chemical form" are often confusing. Addition &1 guidance is provided in Appendix E. (b) Loading of Packages on transport vehicles: 1) Non-full-loads - the requirement for the shipper to p,rovide a highway carrier with the necessary placards is relatively new. Previously, carriers were solely responsible for the provision and application of the { placard. 2) For full-loads of LSA packages, the placard requirement -{ is imposed on the shipper, not the carrier. 3) Inspector's should caution licensee's that in loading ' ell-load vehicles, proper account should be taken w the weight limits and weight distributions that the carrier will be subject to yia local or state regulations when the vehicle is being transported. 5) Receipt of Packages The NRC guidance on receipt and delivery of licensed materials is set forth in Regulatory Guide 7.3, " Procedures for Picking Up and Receiving Packages of Radioactive Material." The package opening procedure should include consideration of special opening procedures if provided by the shipper. l 6) Incident Reporting l This requirement in 49 CFR 171.15 and 171.16 is imposed on the car iees. Inspectors verify that licensee shippers i who act as private carriers have procedures for reporting i to DOT in the event of fire, accident, breakage or suspected contamination involving radioactive materials shipments. Substantial reduction of the effectiveness of the packaging during use should be considered only for the routine conditions of transport. If there is a substantial reduction as the result of an accident, even if major repairs are needed, a report is not needed. Anchor bolts breaking during transport could be reportable while drum puncture by a fork lift would not be reportable. 71.16 7) (Blank) 1 III-10 0
o Transpo'rtatien Activities Procedure No.: 86740B Issue Date: 4/1/80 8) Licensee's Audit Program The audit program should be examined to see that it has becn fully implemented in accordance with the audit plan. All areas of transport activity should be subject to audit on a schedule specifiec in the plan and/or the package approval. Audit findings should be reviewed to see that licensee - identified program weaknesses have been resolved. The resolution of the problems should be reviewed for confor-mance with regulclory requirements. Field implementation of the corrective action should be examined for adequacy. 9) Examination of Packages Unless good judgment is exercised, unwarranted radiation exposures could be received in performing on-site examination of packages. Therefore, the selection and examination of packages must be balanced against associated radiation exposures. It is not the intent that an inspector be exposed to excessive levels of radiation in order to examine several packages of all types of waste. The intent is to limit the " opening" to one package unless the inspector deems it necessary to open more than one package to meet the inspection objectives. When circumstances exist which dictate the need to examine more than one package (e.g. observation of possible free liquids), the examination should be limited, with major consideration being given to radiation levels and contamination potentials. 10) Record Keeping Record Keeping requirements associated with 49 CFR provisions are currently being reexamined. It may be'necessary to develop and promulgate an amendment to 49 CFR or 10 CFR 71 so as to require record keepir.g by licensees in certain areas, e.g. retention of shipping papers. In the meantime, there does clearly exist a requirement for retentior, if the safety analysis report by each shipper of a DOT Spec 7A package (see 49 CFR 173.395(a)). A similar' requirement also exists for retention of special form certifications. (See 173.398(a)(4), Note 1) 1 l III-11
e-r- Transportation Activities Procedure No.: 86740B Issue Date: 4/1/80 APPENDIX A DOT SPECIFICATION 55 N $ 178.250 SpeciGentico 555 metal.en. g 178.250-3 Telding and braring. en.ed, lead er meanium metal. shielded, radioactive material con. (a) When used to join parts of the t iner. container must be performed in a work-manitke manner and shall provide a i W83-1 Compliance, loint ef5ciency cf not less than 85 per-(a) Itequired in an detana. cent. 'nie melting point of brartnr ma-terial mst be in excess of 1.000* F. g 178.250-2 Requirements foe dealgn and construction. $ 1 s8.250-4 Closures. (a) Lead or urantum metal shield to (a) Clorure must be by positive be encased in mDd steel or equally are f astening deiice capable of withstanding resistant metal of minanum wall thick-severe impacts without failure. ness as fonows: (b) Iead oi *Jranium metal shielding (1) One-eighth inch (%") thick for forming part of closing device must be dot more than 6 inches of lead or ura-completely encased in Inild steel or nium metal (see Note ll. equally are-resistant metal. (2) One-fourtu inch (%") thick for (c) Closure must be of off-set design more than 6 inches of lead or uranium where inserted into other parts of the 2 caetal (see Note 1). container. Non 1: Dicknew of lead to tw measured (d) A means must be provided on the trom outer cose or source cartty to nearest closure to accommodate a seal of a type point on outer container wan. that must be destroyed if container is abt I.ead or urantum tnetal shleld to opened for any purpose. oe completely encased so that molten g 178.250-5 Ma rking. lead or uranium rnetal wi!) not now away (a) Marking on.me' container in an or lose its sh!elding e:Sciency if involved unobstructed area. b> cmbossing or die-In a are. The shield must be supported stamping on the container, or on a metal !n the outer container in such manner plate attached to the container by weld-l that it cannot change posttlon under any Ing or brazing in letters and figures at ortiinary cond!ttons. Parts of the shield ht %** in belght as io!!ows: must be so designed that radiation can-(1) DOT-55* * * (stars to be replaced not be " beamed at point where sections by the tare weight of the container stor lo'.n (offset design required). example: DOT-55 850)). These marks (cs Containers we:ghtng more than shall be understood to certify that the 500 poundt must be fitted uith sk!ds or container compiles with all specification j otherrise dmirned so that excessive re r m re!ght will be p-evented on xmm11 areas 3 e words "RADIDACITVE of car or truck Doorn. MA AI'~ (d) Containers wetehtne more than 500 pounds must be provided with books. (3) Name or ermbol (letters) of handles, skids. or other devices to f acul-maker or user assuming responsibility tate handung.- for cotup!!ance with specincation re-quirements; this mst M recorded wh (el Containers must be of such size and design as are necessary to reduce the Bureau of Explosives. the radiation from the container to w*.th!n the limits prescribed in i 173.393 of this chapter. (f) Containers constructed with tub-ing for' drainage purpose must have the opening exterior to the shir,ptne con-tainer plugged or capped. Drain lines must be plurred er capped with a ma-terial whleh wiH have a melt-point at or below that of trad for example. lead hard rubber,or plastic. 4 A-1
+ Trrnsportation Activities Procedure No.: 867408 Issue Date: 4/1/80 APPENDIX B IE Circular No. 78-03 May 12, 1978 PACKAGING GREATER THAN TYPE A QUANTITIES OF LOW SPECIFIC ACTIVITY RADI0ACTI'vc MATERIAL FOR TRANSPORT This circular describes a situation that has occurred at nuclear power facilities and that could occur whenever 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 quantities of LSA material. in packages which are not authorized by NRC. These unauthorized shipments have resulted from inadequate understanding of Part 71 regarding LSA material. Differences between Part 71 and the Department 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. 00T regulations make no mention of the total activity 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 trans-port 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 PCR 71.12 has requirements for the type of container when more than a Type A quan+ l radioactive material is to be transported. LSA material in excess-of a Type A quantity is not exempt from the general license requirements. Several licensees 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 transport such material outside in confines of his plant or other place of use. No written response to this Circular is required. If you require additional information regarding this matter, contact the Director of the appropriate NRC Regional Office. B-1
o Transportation Activitics Procedure No.: 867408 Issue Date: 4/1/80 t APPENDIX C The fC icwinc rticle is extracted'from the December, 1974 issue (Vol. IV, No. 38) of ',he DOT OHM Newsletter OVERPACKING OF R'DI0 ACTIVE PACKAG2S A Frequen'tly questions arise regarding the regulatory provisions for "overpacking" of " bagging" of properly marked and labeled specification packages of radioactive material within an outer overpack enclosure such as a heavy guage plastic bag or a fiberborad carton. At the present time, the regulatory provisions are essentially silent on certain aspects of such arrangements. The Office of Hazardous Materials is currently working closely with the Federal Aviation Administration of the Department to develop proposed rule making to clarify this situation. Meanwhile, the following suggestions are offered as guidance. In the event that multiples of inner radioactive materials packages which are each properly packagec, marked, and labeled are placed within an outer rigid (such as a fiberboard carton) or a non-rigid (such as a plastic bag) enclosure, each such overpack -- 1. Must be labeled as prescribed in S 172.403 of the Hazardous Materials Regulations. The " contents" should be entered on the label as " mixed radioactive materials packages" if more than one type of radioactive material is present within the inner packages. The " number of curies" entry should indicate the sum of the activity of all the contained inner packages. 2. In the case of nonrigid overpacks, is labeled with at least one proper label, along with other required markings which should be affixed to the overpack by means of a securely attached on durable tag. The transport index should be determined by adding together the transport indexes of all of the contained inner packages and not by direct radiation measurement of the overpack. i 3. In the case of rigid overpacks, the transport index should be determined either by adding together the transport indexes of all of the contained inner packages, or by direct measurement pursuant 4 to 49 CFR 173.389(i). Such overpacks should also be capable of withstanding the comprest;co test as prescribed in S 173.398(b) (v), and labeled with two ! Qels as required for a package. 4. Should be marked with the name and address of the shipper and consignee, the applicable shipping name or names from S 172.101 and the statement "inside packages comply with prescribed specifications." C-1
i Tr nsportation Activities Procedure No.: 867408 f Issue Date: 4/1/80 5. Should in no case have a transport index exceeding 10.0. 6. LShould be considered as a single package with respect-to shipping paper docomentation. 7. Should contain inside packages from only a single consignor, in the case of freight forwarders or consolidators, whose identity should be listed on the' shipping papers. 9 9 C-2 s
Transportation Activities Procedure No.: 86740B Issue Date: 4/1/80 APPENDIX D NRC/IE interim position on exclusive use, open transport vehicle exposure rate limits. The following interim position developed by Region III is the current IE position on this matter. EXCLUSIVE USE, OPEN TRANSPORT VEHICLE RATE LIMITS Allowable exposure rates associated with transportation of radioactive material are specified in 49 CFR 173.393 (i) and (j). Although these regulations are easily interpreted for nonexclusive use shipments and for exclusive use, closed transport vehicle shipments, they are not' entirely clehr regarding the allow-ble- ~ exposure rates for exclusive use, open transport vehicles. The following application of these regulations to exclusive use, open transport vehicles has been agreed upon by Region III and State of South Caroline personnel in connectin with Commonwealth Edison Company radwaste shipments to the Barnwell, South Carolina burial site. We intend to use the same interpretation for other licensee-shippers in degion III. 1.) $1000 mR/hr at 3 feet from the external surface of the " package". 2.) <200 mR/hr contact with external surface of outermost container Tmay or may not be " package"). l 3.) 110 mR//hr at two meters (six feet) from the vertical planes projected from the outer edges of the vehicle. 4.) 52 mR/hr in any normally occupied location. 10r.R[hr ((,6' f.--shicided cask v k ~ *7 Package 200 mR/hr 2 nR/hr t l'b m ~ mR/hr I- - l ~ e 0-1 l __-e- ,,}}