ML20125D357

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Comments on Criteria Used for Establishing Max Quantities of Radioactive Matls Which May Be Transported in Type a Packages.Dot Should Consider Whether Comments Have Merit & Whether Criteria Need to Be Appropriately Modified
ML20125D357
Person / Time
Issue date: 04/04/1983
From: Cunningham R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Santman L
TRANSPORTATION, DEPT. OF
Shared Package
ML20125D188 List:
References
FOIA-85-3 NUDOCS 8506120329
Download: ML20125D357 (1)


Text

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APR 4 7993 Mr. L. D. Santman, Director l

Material Transportation Bureau Oepartment of Transportation 1100 Seventh. Street, S.W.

.'ashington, D.C.

20590

Dear Mr. Santman:

l l

The criteria that are used for establishing maximum quantities of radioactive materials which may be transported in Type A packages appear to be non-conservative in two respects as discussed below.

We recomend that you consider whether our coments have merit and whether the criteria need to be appropriately modified.

l Our first coment is that the maximum quantity of radioactive material permitted in a Type A package is based upon an assumption that persons accidentally exposed from released radioactive material or from direct ' radiation should receive radiation doses no greater than l

3 rems to the total body, red bone marrow and gonads; 15 rems to the skin, thyroid and bone; and 8 rems to any other organ.

These doses are higher than those recomended by the International

(

Ccmmission on Radiological Protection (ICRP) for members of the general public.

The ICRP recommends that accidental doses to members of the i

general public be no greater than twice the appropriate annual l

non-occupational limit in any single event.

These doses are 1 rem effective whole body dose equivalent and 10 rems dose equivalent

-to any tissue.

Our second coment is that the maxinum quantity of radioactive naterial pemitted in a Type A package is based 'upon an assumption that the worst accident scenario would involve exposure of members of the public to the contents of a single Type A package.

Vehicles frequently carry more than a single package.

Multiple packages could be damaged in a serious accident.

The basic assumptions for quantities permitted in Type A packages and the consequences of an accident involving multiple packages merit reexamination.

Je will be pleased to discuss our ccaments with you and assist you in evaluating whether changes may be needed in the criteria for liriting the quantitics of radioactive materials in individual Type A packages and in cach shipment of Type A packages.

Sincerely, i i 8506120329 850201 PDR FOIA Richard E. Cunningham, Director j

DOUCHERTY85-3 PDR Division of Fuel Cymle and

,.. rial Cafetv. CSS

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