ML20041D053
| ML20041D053 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/1982 |
| From: | Cobb L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Jay Collins, Engelken R, Haynes R, James Keppler, James O'Reilly 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 | |
| IEIN-80-32, NUDOCS 8203040160 | |
| Download: ML20041D053 (7) | |
Text
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1 I ES 01 E82 MEMORANDUM FOR:
R. C. Haynes, Regional Administrator, Region I i
J. P. O'Reilly, Regional Administrator. Region II 4
J. G. Kappler, Regional Administrator, Region III J. T. Collins, Regional Administrator, Region IV R. H. Engelken, Regional Administrator. Region V FROM:
L. I. Cobb, Director, Division of Fuel Facilities, j
Materials and Safeguards, IE i
i
SUBJECT:
IE INFORMATION NOTICE NO. 80-32, Rev.1:
CLARIFICATION OF CERTAIN REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENTS OF RADI0 ACTIVE MATERIALS The subject notice is enclosed for issuance on February 12, 1982.
It should Le issued to all fuel facility, materials and Pa-t 50 licensees.
A draft copy of the transmittal letter is enclosed for this purpose.
Mai. ling labels and address printouts for fuel facility and materials licensees will be sent under separate cover.
3 L. I. Cobb, Director Division of Fuel Facilities, Materials & Safeguards, IE
Enclosures:
1.
Draft transmittal letter 2.
Information Notice No. 80-32, Rev 1 M
CONTACT:
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(Draft transmittal letter to fuel facility, materials and Part 50 licensees)
IE INFORMATION NOTICE N0. 80-32 Rev. 1:
CLARIFICATION OF CERTAIN REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENTS OF RADIO-ACTIVE MATERIALS Addressee:
The enclosed information notice is being issued as a supplement to the notice IN 80-32, issued on August 29, 1980.
Its purpose is to clarify and amend three par; graphs and the Appendices only to the original notice.
If there are any questions related to the notice, please contact this office.
Sincerely, Signature (Regional Administrator)
Enclosure:
1.
IE Information Notice No. 80-32, Rev. 1 f
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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.
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February 12, 1982 IE INFORMATION NOTICE NO. 80-32 Rev.1:
CLARIFICATION OF CERTAIN REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENTS OF RADIO-ACTIVE MATERIALS J
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 B on which there have been numerous questions and inquiries..Those paragraphs and appendices are superceded as follows:
t 1.
Q.
What radiation limits would apply to shipments being transported on an open exclusive use transport vehicle?
i A.
The constraints of 49 CFR 6173.393(j)(3) and (4) would apply; e.g.,
10 mrem /hr at 2 meters from the open planes projected by the outer i
lateral edges of the vehicle, and 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, j
in its queries to the Department of Transportation (DOT) on the correct interpretation of S173.393(i) and (j), NRC has been l
1 advised that the existing language of S173.393(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 vechicle to 200 mrem /hr I
(such as the same limit applied to the surface of a closed j
transport vehicle).
00T has stated that it is currently taking steps to revise S173.393(j).
In the interim, NRC licensees l
1 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 vechicle, as has been the practice and interpretation of most shippers in the past.
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5.
Q.
If " packages," such as secondary inner drums, (as contrasted to a simple personnel barrier as discussed in Q.4 above), are enclosed within an outer shield, may this shield be considered to be an. integral i
l part of the " closed transport vehicle" when such a shield provides attenuation of-the vehicle radiation levels 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 i
opposed to the " vehicle"?
i 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 f actors:
1 l
L
4 IN 80-32, Rev. 1 February 12, 1982 j
Page 2 of 2 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 00T defini ions of " closed trans-port vehicle" [$173.389(q)] and " packaging" (S171 8), each inner drum within an outer shield integrally attached to the vehicle may be considered I
a " package" provided that each inner drum compiles with S173.393(j)(1),
(1 rem /hr at 3 ft) and also provided that the content within any single inner drum does not exceed 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 j
limit of S173.393(j)(2) (200 mrem /hr).
The inner drums would be marked as packages and the outer enclosure placarded as a vechicle.
6.
Q.
In contrast, under what circumstances would the outer enclosure plus i
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.
I No written response to this notice is required.
If you need additional i
information regarding this subject, contact tha Regional Administrator of 2
the appropriate NRC Regional Office.
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i-1 Attachments:
l 1.
Appendices A and B 1
2.
Recently issued IE Information Notice i
49 CF R 173 3931:110 smem/hr 4's i,f it 113 3'J 3til 10 mrem /he AI ANY POINT 2 m (6 f t) 2 mnem/hr 2 eneem/br A T AfJ ( POffJ T 2 m its it)
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F ftOM Tile VEliTICAL ii ANES PHOJEC1E D F HotA IHf vt HitCAL Pt Af4E PitOJECIE D F HOM IHE OUTE H EDGES OF VEllicE E.
IsY IntE Oult it t AILlt AL SLlHF ACE 2 meem/hr IN cat)
F OF I Hf C AI: 'iff VilllCL E 2OO mrem /he Al Af4 V POlf4 T OfJ THf E M IE Rfl AL e"g F'T' SultF ACE OF THE CAf t OH 9s
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EXCLUSIVE-USE CLOSED TRANSPORT EXCLUSIVE-USE OPEN TRANSPORT.
4.> C F H irm e,> 200..e....i,,,
Appendix A l
Al AfJY POlf4I Of4 IHE E XIE HfJAL SUHF ALE Of IIII PACKAGE IE information Notice 80-32,Rev 1
.0,,,e....n.. A I 3 a t F HOM AN v ACCE SSillE E E X IE HN AL StHlf ACE Of illE I
PACKAGE t
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c W,IHin VI,"cu MoSr 49 CFR 173.393(i) AND (j)
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COMPL Y Wille 49 CF H 177 8421hl, to -
NON-EXCLUSIVE-USE OPEN OR CLOSED G'
TRANSPORT U
Apocndix B IE Information Notice 80-32, Rev 1 WHAT COMPRISES THE PACKAGE?
PEllTINENT CONSIDERATIONS:
- The Definition of a " closed transport vehicle"-see 49 CFR 173.389(91
- 49 CFR 171.8 Defines packaging such that you must consider the
.. assembly of one or more containers and any other components necessary to achieve compliance with the eninimum packaging requirements.:'
j I
e The NRC general license requirements of 6610 CFR 71.7(bl 71.11(b)(1). 71.12(bl. and 71.35 require that any " package" used to ship LSA in quantity exceeding Type A must be designed to withstand standards for norn.al conditions of transport THEREFORE:
INNER ASSEMBLY OUTER ENCLOSURE ENTIRE OUTEf1 IS PACK AGE" IS A PERSONNEL ASSEMBLY IS ENCLOSURE BARRIER OR SIMULATED
" PACK AGE ** \\
IS A SHIELDED "CL OSED VEHICLE" (M AY
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COMPONENT OF HAVE INTEGRAL SHIELDINGl
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IF IF e radiation level at 3' frorn any secondary inner " package" e radiation level at 3' froen any single does not exceed 1 rem /hr (See 173.393(j)(1); and inner container exceeds 1 sem/hr e radiation level at exterior surface of outer enclosure ISee 173.393(jll1); or y
3 argug does not exceed 200 meem/hr (See 173.393(j)(2); and e Activity content within any single inner e Activity content within any single secondary inner container exceeds a Type A quantity as LSA; to g g as
" package" does not exceed a Typo A quantity as LSA; o Q 'u^# S tu o, e r r
THEN THEN
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- The exterior of the outer enclosure is Each secondary inner container is marked as a " package" marked as a" package" 3
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- The exterint or the outer enclosure is placarded as e The entire assemlity must be certified d Vehicle g _,
by NRC as Type A. if LSA material is invoived-ru
- _~ -
IN 80-32, Rev. 1 February 12, 1982 RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No.
Subject Issue Issued to 82-02 Westinghouse NBFD Relay 01/27/82 All power reactor Failcres in Reactor facilities h31 ding i
Protection Systems at an OL or CP Certain Nuclear Power l
Plants 82-01 Auxiliary Feedwater Pump 01/22/82 All power reactor l
Lockout Resulti'ig from facilities holding i
Westinghouse W.' Switch an OL or CP Circuit Modification 81-39 EPA Crosscheck Program -
12/23/81 All power reactor l
Low Level Radiciodine in facilities holding 1
Water Test Program an OL or CP 81-38 Potentially Significant 12/16/81 All power reactor Equipment Failures Resulting facilities holding from Contamination of Air-an OL or CP Operated Systems 81-37 Unnecessary Radiation 12/15/81 All power reactor Exposure to the Public and facilities nolding Workers During Events -
byproduct material Involving Thickness and licenses Level Measuring Devices i
81-36 Replacement Diaphragms for 12/3/81 All power reactor Robertshaw Valve (Model facilitie., holding No. VC-210)
'an OL or CP 81-35 Check Valve Failures 12/2/81 All power. reactor facilities holding j
an OL-or CP 81-34 Accider tal Actuation of 11/16/81 All pcwer reactor i
Prompt Jublic' Notification-facilities holdino System an OL or CP OL = Operating Licente CP = Construction Peisit i
Recently _ issued IE In ormation Notice will be included wten IN No. and issued date are assigned.
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