ML20125D503
| ML20125D503 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1984 |
| 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 8506120377 | |
| Download: ML20125D503 (5) | |
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JUN B 1984 fir. Leon De Santman, Director Materials Transportation Bureau U.S. Department of Transportation 400 Seventh Street, S.W.
Washington, DC 20590
Dear Mr. Santman:
By letter dated April 17, 1984 to R. G. Page of my office, Ronald B. Pope of the IAEA requested comments on the document " Emergency Response Planning for Transport Accidents Involving Radioactive Material", I AEA TECDOC-262.
We have reviewed the document and have prepared the enclosed comments.
We
. ould appreciate your sending these comments along with the Department of w
Transportation's comments to Mr. Pope.
If you would like.to discuss our coments, please let me know.
Sincerely, Original SMne~d by filchard E. Cunninghs.11 Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety, INSS
Enclosure:
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COMMENTS ON IAEA TEC00C-262
" EMERGENCY RESPONSE PLANNING FOR TRANSPORT ACCIDENTS INVOLVING RADI0 ACTIVE HATERI ALS" 1.
We believe the document too often seeks to convince or reassure the reader that the transportation of radioactive material is safe.
Although we believe transportation risks have been minimized, this tone is inappropriate in a document whose purpose is to guide readers in the preparation of plans for responding to transport accidents, however unlikely they may be.
The document would better serve its purpose if it were written in a more objective fashion.
2.
Concepts and information f ran several recent U. S. A. publications should be considered for inclusion of additional information in the report.
These include:,
i o FEMA-REP-5, " Guidance for Developing State and Local Emergency Response Plans and Preparedness for Transportation Accidents,"
March 1983.
DOT p 5800.3 " Emergency Response Guidebook," DOT,1984.
o DUT/RSPA/HTB-81/4 " Radioactive Katerials Transportation Information o
and Incident Guidance," 1981 (currently being updated).
3.
It would be helpful if the document contained a discussion of histories of several different types of transport accidents, including information concerning what occurred, any response actions taken, and where applicable, i
lessons learned.
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- 4..Several of the statements in the existing document need to be modified, we believe, as noted below:
o Paragraphs 2.02.
This paragraph states that transport packages will retain their int 69rity under conditions of handling "anc most forseeable accidents." We believe this statement can be rade with respect to Type B containers, but not Type A containers.
The paragraph also states that "in the vast majority of cases" there would be "no release or...
small quantity releases" in severe accidents. While large releases are unlikely from Type B containers, they may occur from Type A packages.
.o Paragraph 3.01.
We recommend that the planning basis for emergency response plans also include the type and quantity of radioactive materials transported.
Paragraph 3.13 states that an increasing number of Type A packages are o
found in multiple consignments where several packages are held together in an overpack.
We recommend that this statement be deleted or changed so as not to imply tacit approval of a method of packaging which results in greater than a Type A quantity being shipped in a single overpack package, Paragraph 3.14 implies that direct radiation levels from the contents of a o
Type A quantity or multiple Type A quantities cannot result in a radiation hazard.
He disagree and recommend that the paragraph be appropriately changed.
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' o Paragraph 3.16.
We recommend that the postulation of package failures listed in this paragraph include sabotage.
o Paragraph 3.22.
We recommend that this paragraph include examples of "special arrangements."
o Paragraph 3.26.
This paragraph states that a breach of a package normally would affect only the vicinity of an accident site and would not necessitate taking protective actions to protect the general public beyond the immediate area.
This seems to conflict with what is said in Paragraph 3.35.
We believe that a breach of a transport package could in fact result in several miles of roadways being contaminated.
o Paragraph 4.01.
It is probably unrealistic to expect a, carrier to have an _ emergency plan for responding to a transport accident involving
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radioactive materials unless radioactive materials constitute a large part of his business.
o, Paragraph 5.06.
This paragraph states that shipping documents should
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include a 24-hour telephone number for designated response personnel.
We recommend that-this requirement apply only to certain large shipments and not to all shipments.
o Paragraphs 6.12 and 6.14.
We recommend that these paragraphs indicate how often emergency response exercises and drills should De conducted.
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o Definition of " Low Specific Activity radioactive materials" on page 51.
The definition states that such material presents a low to negligible hazard.
Depending on the types and amount of radioactive materials released, as dis' cussed in Paragraph 3.10, LSA materials could present a moderate to high radiation hazard.
Consider, for example, the involvement of reactor resins in a major transport accident.
5.
We recommend that the document discuss the responsibility of the consignor to provide complete and accurate shipment information to the carrier and the consignee.
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