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'o UNITED *TATES 8
NUCLEAR REGULATORY COMMISSION o
,I REGION IV 611 RYAN PLAZA DRIVE,SulTE 1000 g *****,&g ARLINGTON, TEXAS 78011 February 12, 1982 Gentlemen:
The enclosed IE Information Notice is being issued as a supplement to notice IN 80-32, issued on August 29, 1980.
Its purpose is to clarify and amend three paragraphs and the Appendices only to the original notice.
If there are any questions related to the notice, please contact this office.
Sincerely, John T. Collins Regional Administrator
Enclosures:
1.
IE Information Notice No. 80-32, Rev. I 2.
List of Recently Issued IE Information Notices j$$$II 8202190136 820212 PDR ADOCK 0500 5
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IE INFORMATION NOTICE N0. 80-32, REV. 1: CLARIFICATION OF CERTAIN REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENTS OF RADI0 ACTIVE MATERIALS Licensee Facility / Docket Number Arkansas Power and Light Company Arkansas Nuclear One, Units 1 & 2
"'Little Rock, Arkansas
.50-313; 50-368 Nebraska Public Power District Cooper Nuclear Station Columbus, Nebraska
,50-298 Omaha Public Power District Fort Calhoun Station
'0maha, Nebraska 50-285 Public Service Company of Colorado Fort St..Vrain Generating Station
~~ Denver, Colorado
'50-267 University of Kansas 50-148
" Lawrence, Kansas B,
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b Idaho State University
'50-284 RECEIVED 3
~ Pocatello, Idaho FEB1-81982> {
-Brigham Young University
- 50-262 Provo, Utah 6
US bY TIDC Omaha VA Hospital
'50-131 8
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~0maha, Nebraska e
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, University of New Mexico
'50-252 Albuquerque, New Mexico University of Utah
'50-72 & 50-407
' Salt Lake City, Utah
~
US Geological Survey 50-274 Denver, Colorado University of Texas 50-192
~ Austin, Texas Texas-A&M-University G 0-59-& 50-128 College Station, Texas Kansas State University
$0-188
~~ Manhattan, Kansas University of Oklahoma 50-112
' Norman, Oklahoma
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SSIN No.:
6835 Accession No.:
8107230047 IN 80-32, Rev. 1 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 4
February 12, 1982 x
IE INFORMATION NOTICE NO. 80-32 Rev. 1:
CLARIFICATION OF CERTAIN REQUIREMENTS i-i FOR EXCLUSIVE-USE SHIPMENTS OF RADIO-ACTIVE MATERIALS This is a supplement to IE Information Notice No. 80-32, originally issued August 29, 1980.
It is intended to clarify Question / Answer Numbers 1, 5 and 6, and Appendices A and 8 on which there have been numerous questions 4
9 and inquiries.
Those paragraphs and appendices are superseded as follows:
1.
Q.
What radiation limits would apply to shipments being transported on an open exclusive-use transport vehicle?
l.
'A. - The constraints of 49 CFR S173.393(j)(3) and (4) would apply; e.g.,
10 mrem /hr at 2 meters from the open planes projected by the outer lateral edges of the vehicle, am 2 mrem /hr in any normally occupied area of the vehicle (cab).
Note:
As a matter of clarification, it is important to point out that, in its queries to the Department of Transportation (DOT) on the correct interpretation of S173.393(i) and (j), NRC has been advised that the existing language of $173.393(j) does not clearly reflect the original intent of the regulation; i.e.,
to limit the radiation level at-the accessible exterior surface of a package on an open exclusive-use vehicle to 200 mrem /hr (such as the same limit applied to the surface of a closed transport vehicle).
00T has stated that it is currently taking steps to revise 9173.393(j).
In the interim, NRC licensees are urged and cautioned to adhere to a surface radiation level limit of 200 mrem /hr on a package transported on an open exclusive-use transport vehicle, as has been the practice and interpretation of most shippers in the past.
If " packages," such as secon'ary inner drums, (as contrasted to a d
5.
Q.
simple personnel barrier as discussed in Q.4 above), are enclosed within an outer shield, may this shield be considered to be an integral part of the " closed transport vehicle" when such a shield provides attenuation of the vehicle radiation evels to meet the 200 mrem /hr limit of S173.393(j)(2)? Further, what other considerations are there in such a situation in determining what constitutes the " package" as opposed to the " vehicle"?
IN 80-32, Rev. 1 February 12, 1982 Page 2 of 2 A.
This question of defining what constitutes the " package" has arisen frequently and has. created much confusion.
Generally speaking, the criteria to be considered, which are illustrated in Appendix B, include the following factors:
Whether or not any single inner container, e.g., drum has a radiation level of less than 1 rem /hr at 3 feet [S173.393(j)(1)]
Whether or not any single inner container, if bearing LSA material, has a quantity of radioactivity exceeding Type A [S10 CFR 71.7(b),
71.11(b)(1), 71.12(b) and 71.35].
Given the above considerations and the D0T definitions of " closed trans-port vehicle" [S173.389(q)] and " packaging" (S171.8), each inner drum within an outer shield integrally attached to the vehicle may be considered a " package" provided that each inner drum complies with S173.393(j)(1),
(1 rem /hr at 3 ft) and also provided that the content within any single inner drum does not excecd a Type A quantity of LSA material.
In this configuration, the outer enclosure may be considered as the closed trans-port vehicle and may incorporate integral shielding to meet the vehicle limit of S173.393(j)(2) (200 mrem /hr).
The inner drums would be marked as packages and the outer enclosure placarded as a vehicle.
6.
Q.
In contrast, under what circumstances would the outer enclosure plus its secondary inner containers, taken together, be considered as the
" package"?
A.
The combination of inner containers plus the outer shield are con-sidered the " package" if any single inner container has a quantity of radioactivity as LSA exceeding Type A or if any single-inner container exceeds the limit of S173.393(j)(1) [1 rem /hr at 3 ft].
Such " packages" must be certified as Type A by the NRC Office of Nuclear Materials Safety and Safeguards.
No written response to this notice is required.
If you need additional information regarding this subject, contact the Regional Administrator of the appropriate NRC Regional Office.
Attachment:
Appendices A and B
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IEInformation Notice 80-32,Rev 1 u
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LE infonn: tion Notico 80-32, llav 1 WHAT COMPRISES THE PACKAGE ?
PERTINENT CONSIDERATIONS:
o The Definition of a " closed transport vehicle"-see 41 CFR 173.38Sig) 1 e (S CFR 171.8 Dubpos packaging such that you musiconsider the
... assembly of one or more containers and any othis componerits i
necessary to acideve compusace with the minimurypackagisig requiromants.:!.
- The NRC generallicense requirements of sino CFR 7.7(b), 71.11(b)(11. 71.121bl. and 71.36 i
ruquire that any " package" used to ship LSA in quantity exceeding Type A must be desieriod i
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to withstand standards for normal conditions of irwaport THEREFORE INNER Aev~MBLY OUTER ENCLOSURE ENTIRE OUTER IS " PACK AGE *-
IS A PERSONNEL ASSEMBLY IS ENCLOSURE g
BARRIER OR SlMULATED
" PACKAGE" IS A SHJELDED
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s HAVE NTEGRAL SHIELDINGl
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AF IF e sediation level at 3* Irom any secondary Inner ** package" e radiation level at 3' from any single doos not excaud 1 rem /hs (See 173.333(11(1); and loner container excesda 1 rem /hr e rodeution luval at exturior surface of outer enclosure (See 173.383ti)(1h or y,~ g y
i does not exceed 200 mrom/ttr (See 173.3S3(1112); and g4 e Activity consons within 43 single secondary Inner e Activity content within om slogie inner "packago" dona not oncend a Type A quantity as LSA; container exceeds e Type A quantity as LSA; to 3 g g i
ru q g g THEN o << ru rn E!!d
~% ; R e The exterior of the autor enclosuse is NNW-Euch secondary inner container is marked as a " package" marked as a"p ckan."
- The mono,e 91 the outer enclosure is placarded at
- Tlie entire asseintaly asunt be ceraliled
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by NAC as Type A,if LSA materialis involved.
N.
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IE Information Notice No. 80-32, Revision 1 February 12, 1982 LISTING Of RECENTLY ISSUED If NFORMATION NOTICES Information Subject Date Issued To Notice No.
Issued 81-35 Check Valve Failu,,s 12/2/81 All power reactor facilities with an Operating License (0L) or Construction Permit (CP) 81-36 Replacement Diaphragms for 12/3/81 All power reactor facilities
_ Robertshaw Valve (Model with an Operating License No. VC-210)
(OL) or Construction Permit (CP) 81-37 Unnecessary Radiation 12/15/81 All byproduct material Exposure to Public &
licensees Workers during Events Involving Thickness &
Level Measuring Devices 81-38 Potentially Significant 12/17/81 All power reactor facilities Equipment Failures with an Operating License Resulting from Contam-(OL) or Construction Permit ination of (CP)
Air-0perated Systems 81-39 EPA Crosscheck Program -
12/23/81 All power reactor facilities Low Level Radioiodine in with an Operating License Water Test Program (OL) or Construction Permit (CP), and Priority I material licensees 82-01 Auxiliary Feedwater Pump 1/25/82 All power reactor facilities Lockout Resulting from with an Operating License Westinghouse W-2 Switch (0L) or Construction Permit Circuit Modification (CP) 80-32 Clarification of Certain 2/12/82 All fuel facility, materials, Rev. 1 Requirements for Exclusive-and Part 50 licensees Use Shipments of Radioactive Materials Enclosure
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