ML20125D603

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Comments on Schedules of Requirements for Transport of Specified Types of Radioactive Matl Consignments. No Fundamental Problems W/Schedules Found Although Document in Need of Editing
ML20125D603
Person / Time
Issue date: 11/05/1984
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 8506120417
Download: ML20125D603 (5)
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Distribution: FCUF-166 FC Central File NOV 51984 NMSS R/F FCUF R/F RECunningham CEMacDonald /

JMalaro, RES LCobb, IE RGPage Mr. Leon D. Santman, Director JRCook tiaterials Transportation Bureau U.S. Department of Transportation 400 Seventh Street, S.W.

Washington, D. C.

20590

Dear Mr. Santman:

We have reviewed the draft, " Schedules of Requirements for the Transport of Specified Types of Radioactive Material Consignments "

dated August 1984. We have no fundamental problems with the schedules, To this end, although we believe the document is in need of editing.

I have enclosed a number of specific comments. We appreciate the opportunity to review the schedules and hope our connents will be heleful.

Sincerely.

Original Signe'd By Richard E. Cunningham Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated 4

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.NRC COMMENTS ON SCHEDULES OF REQUIREMENTS FOR THE TRANSPORT OF SPECIFIED TYPES OF RADI0 ACTIVE MATERIAL CONSIGNMENTS

.COMPANSION RECOMMENDATIONS TO IAEA SAFETY SERIES NO. 6 i

Page No.

Coment 1

The "I. MATERI ALS" heading should be clarified--are radioactive wastes included?

All statements or entries in the Schedules should be in complete sentence fonnat.

Statements (a) and (b) are examples of statements that should be expanded to sentence format.

Statements (a) and (b) should also state clearly that the materials described may be shipped in excepted packages. The other hazardous characteristics mentioned in~ statement (c) should be explained.

Is statement (c) describing an excepted material or a restriction that applies to statements

(,6,) and (b)?

3 The "6. MIXED PACKING" and "7. MIXED LOADING" hea~ dings should be defined.

S.

The references under "14. OTHER PROVISIONS" by themselves are not very helpful.

Explanatory text would improve this section.

o 6

Would it be advisable to combine Schedules I and II?

6 Comments on entries in Schedule I also apply to corresponding entries in other Schedules.

16 No rationale is provided for statement 5(b).

2[

Does "Other Items" in statement 6(a) refer to nonradioactive items?

Is the statement under "8. LABELING AND MARKING OF PACKAGES, FREIGHT CONTAINERS, TANKS AND OVERPACKS" that FISSILE MATERIAL is not permitted to be transported as LSA-1 MATERIAL correct? Are not certain quantities excepted?

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Comment 25, 33, 42 Actions appropriate to achieve the needed level of

" segregation" should be discussed.

i Annex-II In the table entitled, " Transport Index Limits for j

Conyeyances and Freight Containers," is the n.a. entry appropriate for the " FREIGHT CONTAINER - small" row, "In EXCL. USE/ FISSILE MATERIAL" column? Same coment applies to " PASSENGER AIRCRAFT" row, both, "IN EXCL. USE" columns.

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PART 73

  • PHYSICAL PROTECTION OF PLANTS AND MATERIALS I 73.37 fleguiremente ter physisel (iv) Implement the procedures by a third vehicle occupied by at least protection et errosaaeed reacter tues m developed in accordance with one armed escort.

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parasrdph (b)(2) of this section.

(2) A transport vehicle not within any (a) Performance objectives. (1) Each (4) Include a communications center heavily populated area is:

licensee who transports. or delivers to a at a designated location, which will be (1) Occupied by at least one driver and carrier for transport in a single staffed continuously by at least one one other individual who urves as shipment. a quantity ofirradiated individual who will monitor the progrus escort: or reactor fuel in excess of 100 grams in net of~the spent fuel shipment and will (ii) Occupied by a driver and ucorted weight of irradiated fuel, exclusive of notify the appropriate agencies in the by a separate vehicle occupied by at cladding or other structural or packaging event a safeguards emergency should least two escorts: or material, which has a total external arisa.

radiation dose rate in excess of 100 reme (5) Provide for maintenance of a (iii) Escorted as set forth in paragraph per hour at a distance of 3 feet from any written los by the escorta and (c)(1)of this section.

accessible surface without intervening communications center personnel. for (3) Escorts have the capability of

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shielding. shall establish and maintain, each spent fuel shipment, which will communicating with the or make arrangements fer, and assure include information describing the communications center,locallaw the proper implementation of, a physical shipment and significant events that enforcement agencies, and one another, protection system for shipments of such occur during the shipment, and will be through the use of:

material that will schieve the following available for review by authorized NFC (1) A citizens band (CB) radio objectives:

personnel for a period of at least 1 year available in the transport vehicle and in (i) Minimize the possibilities for following completion of the shipment.

each escort vehicle:

radiological sabotage of spent fuel (6) Provide that arrangements have (ii) A radiotelephone or other NRC.

shipments. especially within heavily been made with locallaw enforcement approved equivalent means of two-way populated areas: and agencies along the routes of road and voice communications available in the lii) Facilitate the location and rail shipments, and at U.S. ports where transport vehicle or in an escort vehicle recovery of spent fuel shipments that vessels carrying spent fuel shipments committed to travel the entire route; and may have come under the control of are docked. for their response to en (iii) Citizens bend (CB) radio and unauthorized persons.

emergency or a call for assistance.

normal locallaw enforcement agency (2) To achieve these objectives. the (7) Provide for advance approval by radio communications in any local law physical protection shall:

the NRC of the routes used for road and. enforcement agency mobile units used (i) Provide for early detection and

rail shipments of spent fuel, and of any for escort purposes.

assessment of attempts to gain

U.S. ports where vessels carrying spent (4) The transport is equipped with unauthorized access to, or control over. ; fuel shipments are scheduled to stop.

[ NRC-approved features that permit (8) Provide that shipments are

, immobilization of the cab or cargo-

[ spent fuel shipments; m.

(ii) Provide for notification to the

' carrying portion of the vehicle.

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  • appropriate response forces of any spent ; planned so that scheduled intermediate stops are avoided to the extent

[5] The transport vehicle driver has fuel shipment sabotage attempts: and practicable.

been familiarized with, and is capable of (iii) Impede attempts at radiological (9) Provide that at least one escort implementing, transport vehicle sabotage or spent fuel shipments withm.

maintains visual surveillance of the immobilization communications,and heavily populated areas, or attempts to shipment during periods when the other secunty procedures.

illicitly move such shipments into shipment vehicle is stopped, or the (d) Shipments by rail. In addition to heavily populated areas. until response shipment vesselle docked.

the provisions of paragraph (b). the forces arrive.

(10) Provide that escorts (other than physical protection system for any (b) Generot requirements. To achieve members oflocallaw enforcement portion of a spent fuel shipment that is the performance objectives of paragraph agencies, or ship's officers serving as by rail shall provide that:

(a) of this section. a ph sical protection unarmed escorts) have successfully (1) A shipment car within a heavily system established an maintained, or completed the traming required by populated area is accompanied by two arranged for by the licenses shall:

Appendix D of this part.

armed escorts (who may be members of (1) Provide for notification of the (11) Provide that shipment escorts a Id h dem pd at Nuclear Regulatory Commission in make calls to the communications center least one of whom is stationed at a advance of each shipment. in at least every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to advise of the location on the train that will permit status of the shipment for road and rail observation of the shipment car while in accordance with I 73.72 of this part.

(2) Include procedures for copmg with shipments, and for sea shipments while circumstances that threaten deliberate shipment vessels are docked at U.S.

2) shipment car not within any damage to a spent fuel shipment and ports.

heavily populated area is accompanied with other safeguards emergencies.

(c) Shipments by road. In addition to by at least one escort stationed at a (3) Include instructions for each escort the provisions of paragraph (b), the location on the train that will permit that, upon detection of the abnormal physical protection system for any observation of the shipment car while in presence of unauthorized persons, rtion of a spent fuel shipment that is t

vehicles or vessels in the vicinity of a road shall provide that:

  • f3)$corts have the capability of spent fuel shipment, or upon detection of (1) A trans rt vehicle within a

""'**'I a deliberately induced situation that has beav 1y Popu eted area is-.

communications centee and locallaw the potentiaI for damaging a spent fuel (1) Occupied by at least two enfo* cement agencies through the use of shipment, the escort will:

individuals, one of whom serves as a radiotelephone. c.r other NRC-(i) Determine whether or not a threat escort, and escorted by an armed approved equivalent means of two.way

esists, member of the local few enforcement (ii) Assess the extent of the threat,if agency in a mobile unit of such agency:

, (*y""",

j, *hich shall be (hilInform locallaw enforcement (11) Led by a separate vehicle occupied the provisions of paragraph (b) the (e) Shipments by sea. In addition to i

j agencies of the threat and request by at least one armed escort, and trailed physical protection system for any assistance: and portion of a spent fuel shipment that is i

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l September 1,1982 73 12 i

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PART 73

  • PHYSICAL PROTECTION OF PLANTS AND MATERIALS (iv) A statement that the information by sea shall provide that:

described belowin 9 73.37(f)(3)is (t) A shipment vessel while docked at required by NRC regulations to be a U.S. port within a heavily populated protected in accordance with the eres. le protected by:

requirements of l 73.21.

(t) Two armed escorte stationed on (3)The licensee shall provide the board the shipment vessel, or stationed following information on a separate on the dock at a location that wdl permit enclosure to th.e written notification:

observation of the shipment vessel: or (1)The estimated date and time of (ii) A aiember of a locallaw departure from the point of origin of the enforcement agency aquipped with

shipment, normal LLEA radio -- _

"- tions.

(ii) The estimated date and time of who la stationed on board the shipment entry into the governor's state.

wesel w on es dock at a locadon est wdl permit observation of the shipment (iii) For the case of a single shipment h schdeis eland W 3

shipawnt vessel. while within schedule of any subuquent shipant, a

' US territorial waters, or while docked statement that schedule information I at a U.S. port not within a heavily must be protected in accordance with populated area. is accompanied by an the provisions of I 73.21 until at least to escort, who may be en officer of the days after the shipment has entered or shipment vessel's crew, who will assure originated within the state.

that the shipment le uploaded only as (iv) For the case of a shipment in a authorised by the licensee.

series of shipments whose schedules are (3) Escorts have the capability of a: related, a statement that schedule communicating with the

  • Information must be protected in communications centw and locallaw 0 accordance with the provisions of enforcement agenc6es through the use of g 73.21 until10 days after the last 4

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a radiotelephone, or other NRC-shipment in the series has entered or approved equivalent means of two-way originated within the state and an voice commumcanons.

estimate of the date on which the last shipment la the series will enter or originate within the state.

(4) A licensee shall notify by telephone or other means a responsible I {(.

individualin the office of the governor 1

(f) Prior to the trunsport of spent fuel or in the office of the governor's within or through a state a licensee designee of any schedule change that subiect to this section shall notify the differs by more than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from the ernor or the governor's designee. 'Ilie schedule inforrnation previously i

neee shall comply with the following furnished in accordance with criteria in regard to a notification: (1)

I 73.37(f)(3), and shallinform that The notificauon must be in writing and individual of the number of hours of esat to the office of each appropriate advance or delay relative to the written speernor er the goeermer's desipse. A

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adent y days g g,j 3,,,,,ggg,g,g,,,,,,,,,p,y,,,,

g and other ladividuals, whether or not transport of a shipment wnhin or licensees of the -=6w who r

through the state. A modneedom receive schedule information of the kind deHwul by momengw must reach 6e specf fled in 173.37(f)(3) shall protect

office of the sommor or to gowmor s that information ~ gainst unauthorized a
designee at least 4 days before treasport disclosure as specified in l 73.21.

of a shipmentgrithin or the 6

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state. A list of the mailing of

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governors and goeernors' designess is available upon request from the Director. Office of State Programs. U.S.

Nuclear Regulatory e--ww Washington, D.C.2DESS.

(2) The notification must laclude the fouowinginfonnation:

(i)1he name, address, and telephone aussber of the shipper.amerior and receiver.

(ii) A description of the abir===t se specified by the Department of l

'hanoportation in de CFR 9172.302 and 8tra. age (d).

(iii) A listing of the routes to be used j d.,

within the state.

l 73-13' September 1,1932 1

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