ML20126F417
| ML20126F417 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-0831, NUDOCS 8103130497 | |
| Download: ML20126F417 (151) | |
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ADVISORY CO!C4ITTEE ON REACTOR SAFEGUARDS In the Mat: tar of:
SUBCOM'iITTEE OM RADICACTI"E MATERIALS AFTERNOON SESSION 185 thru 269
. arch 10, 1981 paczg:
M DATE:
Washington, D. C.
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1 3R. E!ESS:
Where in the sta te - is this usually.
2
'a d mini st e re d ?
3-Y E
,*:U s s 3 ;.U ?.E R :
It is administered by the state' 4 radiation control unit, which is usually. th e health 5 department, then they draw on.'other state. agencies.as they 6 need them.
For example, if'they need engineers, geologists, 7 and so on, they so to the'other' departments as.necessary.
8 A"large Ucrtion Cf the SEC's state agreement 9 pr0g ra m is to provide technical assistance to the states on 10 any problems they have.
'de have a staf f of - technical 11 people, largely with a health ;hysics type tackground, to 12 provide assistance.
Then, we also ;C to II.E, N.M E S,- c r 13 standards.
14 ME. SIES3:
You said, we have a list of suggested t
15 state regulations.
They are not required to adopt that?
16 ME. NUES3AUME?:
The way the system works is that 17 under the Atocic Energy Act, Section 274, a state may l
18 request to entar inte an a;reerent with the.YFC whereby the 19 NEC will discontinue its regulatory authority fer certain 1
20 meterials, and transfer that
.t u t ho ri ty to the state, and the r
21 state vill assume that authority.
22 The :aterials are hyproduct :a t er ial, scurce 23 material, and rpecial uclear material.
.Then recently two 24 separate cateccries were added, low level waste disposal, 25 and uranium milling, and uranium ?ill tailin7s cont:01.
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the states can enter into an' agreement-for any en category, 2
any one or more ca tego ries of those ma terials.
3 As ! said, we.have 26 agreement states new who are 4
regulating approximately 12,000 licensees' total.. :So the 5
total' population of-licensees.in'the 25 states-regulated is 6 somewhat, higher than the number tha t the SEC regulations.
^
7
.The Tct says that the states, to the extent 8 practical, will kee~p their. program ~cczpatible with the NRC.
9 So it is really a hest efforts type'cf situation, elthough 10 there is reserve for the NEC to either suspend an agreement, 11 in the case where it is determined there is a radiclogical 12 emergency in the state'that the state is not handling 13 properly, Or to actually cancel an agree.ent Out, and.the 14 state has the Opportunity to ha ve a hearing.
15 These are reserved powers th a t. we would.he 16 expected.t0 exercise, and there are cases where the state 17 was not acted properly to protect health and safety in a 18 timely way, and where essentially they were not accepting 19 cur assistance, which is alwayc available' to the.t.
20
?E. S'ESS:
So if they den 't meet sees level, you 21 can end the a ;reeme n t?
22 ME. ;iU S S E A UIR :
Yes, that is right.
23 YE. SIISS:
On s scalc of zero to 1CO, takin; the 24 NPC as 100, where would you place the states' maximum and 25 m in i:':m avers 7a in their effectiveness in protecting the 1
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1 ; health andt safety.of the public?
2 MR. NUSS3AUMER:
I really haven't been in tha t 3
program long enough to answer that question.
I think some i
4 states are really strong in some areas, and may be weaker in 5 others.
The states are very strong.in the inspection area.
6 They do more inspections than the NEC does, I think 7 primarily because they.are closer to the ' people-the y are 8 regulating in some respects.
9 Some states do a good jet on licensing, and others i
10 ve agree with their decision, but their documentation-leaves 11 something to be desired.
In other words, they don't 12 document their reviews or.SAE, fo'r example.
13 MR. SIISS:
An agreement state would have no i
14 packaqe approval responsibility, since they adopt ~ DOT.
So i
16 MR. NUSS3AUME3 Yes.
17 M9. SIISS:
Their f unction, then, would be 18 licensing the packsge user.
19 M?. "USS3AU!EE:
Ihat is right.
20
%R. SISIS:
? om the point of view cf safety, that l
21 principal concern there is that the "1ser have a suitable OA 22 program, OC program, and that he be inspected for compliance 23 on some basis.
Then the transport in en s si.tilar basis.
24 So if the state does the inspection, they review the CA 25 program.
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1 MR. MUSSBAU ES:
Only for. operations.
They' den't i
2 really review the kind of CA program that Chuck Mcdonald 3 gets from the licensee.
4 ME. SIESS:
- ih y not?
5
-l ME. NUSSBAU"ER:
This is an.tres that-needs to be,
6 filled in right nov.
The states feel.that the EOT should.
7 enact OA requirements for shippers that are not-covered by 8'
NEC re;ulations, rather than have 25 states each putting in-9 separate requirements.
That is an area that is open and
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10 subject.to some consideration ~at the present time.
11
- 52. SIESS:
If the s'.ates don't want to do it, 12 the y could simply let NEC do it, couldn't they?
You say 13 tha t the acreement states can agree on any as;ect of this i
14 that they want.
15 ME. MUS$3AUMEE.
Only for the entire category of 16 materials.
17 ME. SIE35:
Shipping is not a category where they 18 could?
19
%E. SUSSEAUMEE:
Sc.
t 20
- 13. S!ESS:
So if it is a non-agreement state, the 21 NEC licenses the user, in the course of which ycu review 22 their OA progrsz, which is really the control over how well 23 the package is put together, and how they follow the 24 procedures.
J 25 ME. SUSSEAU'EE Yec.
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ME. SIESS:
Eut the agreement state does not i
2 necessarily do that.-
3 MR. NUSSEAUMEE They don't require an equivalent 4 type of' submittal to the one that cart 71 requires.- They 5 would require that the licensee have procedures for loading 6 and closing the package,-and they would inspect that, but it 7 would not get back.to something like fabrication of the 8 package.
9 MR. SIESS:
No. -
10 UE. NUSSEAUMER:
Or the maintenance of a packace.
11
- 13. SIESS:
Maintenance is a user's 12 r es po nsi bili t y, or is the primary certificate holder?
13 MR. NUSSEAUMER:. The maintenance, the only hold.ve I
14 would have would be on the licensee.
'I think we would icok i
15 to the licensee to assure us that the maintenance had teen i
16 p er f o rm e d, rega rdless of whc performs it.
17 ME. SIESE:
That is what you said.
It is the 18 responsibility of the licensee to see that the cark is in 19 good shape.
The caske don't come under state agraements.
20 MR. SUSSEAUMIE:
No.
j 21 ME. SIESS:
Eut the package they have got is in 22 suitable f orm, and meets all the requirements, and th a t it 23 is loaded and closed properly.
These are really what you 24 are concerned with from a safety standpoint.
~".e states 25 vould net do as good a ob on that, or as complete a _dob as t
ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W, W ASHINGToN, O C. 20024 (202) 554 2345
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1 would the NFC.
2 M3. NUSS3ADMI3:
I would say that the program is 3
not as formal.
It is not f o rmally set down in regulations 4 as Part 71 does it.
5
'E.
IUDANSr Eut it ic not necessarily deficient 6 it any way.
7 MR. SIESS:
It just, depends on what weight you 8 give to a
".A program.
Some peccle think that a OC program 9 is no good unless you have a CA program, or that the 10 procedures are no good unless you have a CA program.
Some 11 people think that CA programs are just f o rm ali ti'es, and just 12 pa;er.
They assume a CA program has really no use except to 13 take up space on the bookchelt.
They could de just as good 14 job on psck aging things up and shipping them cut withcut a 15 ;A program as they can with it.
I am not sure that that is 16 a good assumption.
17 ME. NUSS3AUMER:
For the NRC, the screement state 18 licencees a re required to rave radiation safety rrccedures 19 that cover receiving packaces, surveying them, and se on, 20 looking for contamination or excessive radiatier level, as 21 well ac packaging radicactive aterials fer chi; ment.
Both 22 incoming and cutqcin;, these procedures are required.
23 MR. SIESS:
Those procedures are reviewed?
24
??. NUSSEAUMEE:
They are reviawed and inspected.
25 ME. SIISS:
Eut whe th e r they fcllow these ALOEAScN REPORTING COMP ANY, INC, 400 VIRGINI A AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554 2345
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I T-procedures, is that determined?
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2 ME. NUS5BAUMES:
That is part of the inspection l
3 program, yes.
i 4
YR. SIESS:
How do you determine whether. a -
7 5 procedure has been followed without a CA program?
ri 0
MS. N USSB A UM ER:
There is a O A progra'm -in tha t you 7 ' have.to kee p survey records, and records _of what.you have i
8 done.
Coeration is kind of production oriented, and the 9 inspector will review the actual operation taking place.
j
~
i 10 MR. 5:ESS:
Let me ask McDcnald.
Do you think 11 there is any significant difference'between the performance 12 of a licensee in an agreement state than an NFC licensee?
13 R. MCDONALD:
I really don ' t know wh at the record t
14 would show as far as the lost packages, or aishaps in the i
15 t ra rrs po r t.
We may be able to break it down from the 16 records, but I have not made an attempt _to do that.
We 17 might be able to tell somethin; from that.
18 MR. SIEES:
Your experience really doesn't give 19 you much basic for saying that, does it?
i 20 MR. icDONALD h.
e i
21 M3. SIESS:
You just don't have that much to do 22 with those people.
23
'3.
NUSSEAUMEP:
Th*re are some data we could look 24 at it.
The three burial grounds for low level waste a re in 1
25 agreement statss.
The agreement states monitor incoming
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1 shipment.
The' resident inspector there would monitor all' 2-incoming s'h i;:en t s.
For a while the NEC had pecple there i
3 continuously dcing the same thing.. I think now the NEC's 4
program is to do that'so many weeks'out of.the year, or-5 something like~that.
+
One week a month'.
7 MR. NUSSEAUYER:
The type.of shippers who were.
8 shipping vastes into these' burial crounds, as f ar as t
9 violations are concerned, from'the data'I.have seen, I don't
)
10 seem to see any distinguishable difference'between NRC 11 licensees and agreement state licensees.
12 5R. BENDEE:
The issue is on the shipping side 13 rather than the receiving side where the deficiencies might 14 be found.
t 15 ZE. SIESS:
From the receiving re co r d. s, they could P
16 not see much difference.
17
%?. SHAPPEET:
They were ine;ecting incoming j
.t 18 shipments to the burial ground from the standpoint of are 19 the packages leaking, or are they put together properly, are-20 the bolts, tights, the gasketc in place, the radiation levela 21 within the standards, and so on.
22 What I an sa ying ic, where they facnd items of 23 non-compliance, I den't believe that you could ray that the 24 agreement state licensees are doine a better c: worse job.
l 25 It is pretty much 5C-50.
4 4
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MP. SIESS:
Any nuclear' power plant, whether it is 2
in an a;ree:ent state er not, is an 'i?C licensee.
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3 wR.
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4 ME. SIESS:
The f uel f ab rica tCr is an NRC 5
licensee.
6 MR. NUSSEAUMIE:
Yes.
7 MR. SIESS:
Isotope producers, cadical isotcpes.
8 MR. vAEr They could be either.
9 20 SIISS:
Hospitals are mostly waste shippers; 10 is that right?
11 MR. GRELLO:
Hospitals =cstly use brokers, and 12 they usually ship th e m se l ve s.
13 ME. NUSS3AUMIE:
They have a service ecipany to 14 pirk uc their vaste.
15 MR. SIISS:
That would be a licensee?
16 ME. NUSSSAUMI?:
Yes, that vould be a licensee.
17 M ?.. SITSS:
In an agreement state, he sculd have a 18 state license.
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i 20 ME. GFIllC:
MOst of the br:kers are state 21 licensees.
22 MP. SIESS:
Do you mean that you don't have 23 brokers in n c n -a g re e m e n t states?
24 MR. G?. ILLO :
Thcre are two er three major enes.
25 ME. NUSE3AUMI?:
They are in b o th a re a s.
ALDERSON REPC AT NG OOMPANY, INC.
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"2.
SIESS:
The' people that are fabricating-2 - r ad io g ra ph y equipment, an d so f orth.
j i
3 vR. NUSSBAUP.ER
-They would.be either..
4 MR.-SIESS:. -!f they a re in an agreement state, i
5 they would be a. sta te licensee?
6 v,g. :NUSSE AUM ER :
Yes.-
In-the fuel cycle, e
t 7 lic en sees a r e RC.
But when you get into the: radio-isotope 8 licensees, they could be either.
It just depends on their 9 geographic locatica as to whether they a re EC c r 'a g ree men t 10 state licensees.
11
- 33. BENDEE:
What about the mill waste, are they 12 mostly in. agreement. states?
l 13 ME. SIESS:
. tills?
)
14 YE. SINCIE:
No, mill tsilinas.
15 vE. s:USSBAUMEE:
I think tha t it is. pretty evenly 16 split right now.
New Mexico, ColoradC and Texas, which are 17 bic milling states, are all agreement states.
- Wyoming, 18 which is another ltr;e milling state, happens te be NFC 19 licenred territory.
20 SE. SIIIS:
Cn the schedule here it says, 21 Surveillance Frograms.
22 "E.
NUSSEAUMIE:
That is the second tcpic.
23
'! ?. SIISS.
That is hat I thought.
24 ZE. LUSSEAUZIE:
We thought that this progra 25 might be of interest to the subcommittee.
It cot started ALDERSON REPORTING COMPANY !NC.
400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 shortly af ter the Delta inciden t that was referred earlier, I
2 where the gasket was left out of the package en an airline, 3 and it contaminated luggage, and so on.
This was an effect 4 to track all this down.
5 The states have always had a strong interest in 6 t =.nsportation, both in knowing what the basis of the 7 standards is, and what is coming through their particular 8 locality, in order to ;1an properly f0: any emergency if it 9 should occur.
10 3ecause of their interest, the NEC and the DCT 11 developed a progran where they would provide ma tching funds 12 to the state who was interested, whereby the state radiation 13 peo ple would 00 out and monitor shipments a s they were 14 occurring.
15 They would, for example, go tc airports, truck 16 depots, weighing stations.here trucks came through, and 17 they would cather th e sta tis *.i ral d a ta abcut the shipments, 18 and also measure the radiation levels and determine 19 compliance.
Where they found itens of non-compliance, they 20 would refer these to either OLI Or NEC for fellow-up 21 enforcement action.
'enefit of allowing the 22 The progran had the ride r
23 state people to becc.me familiar with tranr;crtation, so when l
24 the people in their state raised questions, they were in a 25 good ;csition to respond rather than ". ave the Federal ALDERSCN REPORT;NG COMP ANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON. 3 O. 20024 (202) 554 2345
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government come in and do it.
2
~ The grants run about $20,000 a year.;to a. state.
l 3 Different states have come in and gone.out.of-this program.
4 over'the-lact'several years.
Ei;ht now there are six states 5 in the.p'ogram.
I think the benefits, outside of their r
6-being able to talk.to their own citizens about 7 transportation, have been tha t in la rg e measure through this.
8 prograc they identified 'a potential problem with transport 9 workers handling a large number of' medical' packages.
l
~
10 Their findings indicated tha t this. group of.
11.
people, even though they were not officially classed as 12 radiation workers, were. receiving tore annual exposure than 13 the standard would permit for a member of the public.
They 14 were receiving exposures comparable to radiation workers, 15 yet they were not beinc instructed in the fact that they-16 were being ex;osed to radiation, and that precaution should 17 be taken to protect against-excessive exposure.
18 I think that both NEC and DCT are now focusing on 19 this problem to see whether we need to institute some kind 20 of controls over certain of these people that pick up these 21 medical packages, la rr;ely fro airports, and deliver them to 22 hospita.lc in vanc and other small trucks.
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1 sometimes wa y beyond the 2 F. E per hour limit.
2 fg gA;K:
Did you say that thisivas discovered'by.
j 3 the states, or by you and.the states?
4 fB. 50SSBAUMIR:
It was one of the. items that this t
5 transportation surveillance program found from the studies P
6 and surveys.
We had in the past' kind of suspectei that 7 there could be a problem, but've never.had any' data until 8 thase' people vent Out and did it.
9 MR..SIISS Y0u':ean that there were people' in the 10 business of transporting r sdioa ctive ?.s te rials, er just 11 people who picked up any kind of material.
' i 12
- 13. NUSSEAUME3:
It is larcely nedical11sotopes.
13 They are in' the business. cf mee tin; tne plane'at the 14 airport.
15 MP. SIIss:
These are specialists who handle 16 radic-isctopes.
17
.13. '?USS3 A UMI? :
Yes.
18 MR. ?!ISS:
They haf never been instructed about 19 the effects of radiation and so forth?
20 TE. MARK:
These are tha van drivers, and not the 21 guys at the hospit al.
22
- 15. SIISI:
Yes, the van drivers.
Thay were 23 spending all of their time doing this sert of rtuff, and 24 they had never been instructed.
It seems fairly obviously 25 that they should nave kncun.
+
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MR. NUSS?AUMIR:. They knew what they..were 2
handling.
If you are an.NEC licensee, you have to comply l,
3 with Part 19 and Part 20, which are.the provisions that you 1
4 have instructions on how you protect yourself against 1
5 exressive exposure, an'd wha t the effects of radiation 6 exposure are.
c e
7
- 33. sIrss:- I t' is'just incredible to me tha't the 8 people who were doing that kind of work had.never been told 9 what they were doing, and what.the possible harards were.
i 10 Of course, the hazards are probably not as great a s gat ting -
11 killed in the automobile accident, but still -- They i
12 probably did not instruct them in driving, either.
13 dR. SUSS? AU?.IR:
This particular situation is kind 4
14 of an anomaly in the transportation area, cecause generally l
15 we expect the radia tion levels f rom the packages are set lov 16 enough so that the people who handle them routin=ly should 17 not receive any excessiva expcsure.
18
??. SIISS:
It is ruch an obvious ancmaly that !
19 just don't see 'how it could have been overicoked.
20 "R.
NUSS?AUMI?:
The pcint I am trying te make is f
21 that thrcugh this program they were able to collect and 22 assemble the da ta that we acw have, so that some acticn can 23 be taken.
24 FI. SIISS:
What abcut the people who fly the 25 airplanes that do the same thing; ire they in the same i
i 1
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category, or do they know what to d'o with them?
i 2
M R., aOSSBAUZEE:
They know what they are.doinq l
3 now.
4
'33. SIESS:
There are-some cperaters that run 5 little. charter planes f or r adio-pharmaceutica 1' products ?!
E 6
MR. NUSS3AUMER:
Yes.
7 MR. SHAPPERT:
Has this'been'a problem with
-l
~
8 primarily Type'A packages?
9 1R'. NUSSBAUME.R Yes.
10 1R. SIESS:
It is interesting.
i 11 hR..NUSSEAUMEE:
You know, they are small and 12 there are so many of them.
13 dR. SIESS:
If they are classified as radiation I
14 workers, then they are required to get certain instruction.
15 3R. ;;USSE AUMIE :
Yes, and have personnel 16 monitoring, and so on.
i 17
- 32. SIISS:
De they get paid any more for 18 harardous d uty?
19 MR. NUSS5AUXER:
No.
l 20 Some of the companies do'have progra.r where they
{
t 21 do monitoring.
They do put film badges on their people, but 22 it is not universal, and th e reason for that is. th a t there 23 is no specific reculation in this area.-
t 24 ME. SIESS:
If you are a van driver, wh+re do you 25 put the film hadge; in your back-pocket?
)
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'f 2. NUSSBAUMEF The other benefit of the program
- 3 2
was that by pulling-all.this information in, we were able to 3 get'some data on what was being shipped where.
Some of the' 4 data was used in the generic EIS on transportation, 0170.
5 The' program is beginning to change, though.
6 Mainly DOT would like to see this program become more of an 7 enforcement program, where the sta tes where they find 8 somethin; wrong would go ahead and tak e ' th eir own 9 enforcement action.
l 10 I think in the future, it may well be that the NEC i
11 vitrdraws from this program, DCT will fund it totally, and I
I 12 then. hey will use it only to detect viciations, but also to 13 take e;'f orrement action.
We are somewhat leary of this 1
14 because sone of the'enforcenent actions can get quite 15. protracted and tak-up a lot of time.
16 ME. s!Iss :
I suspect that the program for j
17 enforcement action and a program to educate and gather 18 statistics are completely incompatible.
19 M ?.. NUSSF. AU::I? :
That is right.
20 d?..?!ISS:
You learn a whole lot less when you 21 put in an enforcement progran.
22 YF. NUS53AUMEPs The need for gsthering 22 statistical data in this ;rogram, I think, is diminished by 24 the fact tht: Sandia is now co puteriring al?. ef the i
wi:1recuk.re 25 incident d a ta.
The ICT nev : uting rule after r
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the fact reports to DCT ci shipments that are made and what 2 routes they take, and all this will be computerired.
So in 3 the future'we should have a pretty good data base on what 4 kinds of materials are moving where.
5 Thir is about all I have to say en this.
6 3E. SIESS:
Thank you very much.
7 We have the Standards Office f or about two hours.
8 Don, you said that you were a let faster than that.
How 9 fast are you?
10
'f E. TALAR 0:
I intended to spend about five 11 minutes givina a broad br.ush idea of the different projects 12 that we are working on in standards, and then to dig into, 13 to the extent that the group vants to get inte it, the 14 studies that we have on the environmental and impacts of 15 risk in tran stn rta tion., pa r ticula rly N"2ES C710 and the 16 follow-up urban transportation study.
17 ZE. S!ISS:
Cn the environmental studies, we have 18 some f amiliarity with, because the s u b c.o m m it t e e was 19 reviewing that project.
I guess we are through with that, 20 since have new seen a SEC? that says that there is no need 21 for rulemakin;, and we were just heing asked to keep 22 informed so that we co uld comment on the rule wnen it was 23 proposed.
So if there is no rule, there is no cc ment.
24 Why don't you give us the first part of it, and 25 then let me ask a few cuestions shout the last part.
We ALCERSoN AEPCRTING COMPANY. INC 400 VIRGINIA AVE.. S.W., WASHINGTCN. O C. 20024 (202) 554-2345
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know.enough about the environ.: ental studies to ask some 2
guestions.
3 MR. ALARO:
Why don't I briefly go through tih e m.
i 4
ME. SIESS4 We are a:Lnly interested in terms of i
5 getting some idea of the proportion of the' risk that is 6 contributed by these kinds of transportation packages, and 7
t-get-some perspective on the nature of the problems.
j 8
MR. MALAR 04 T.he first slide is on th e principal i
9 objective of the office, and.that is to develop the' j
10 regulations and guides that are necessary to keep them up to s
11 date.
The principal areas of interest that we are lookino 12 at righ t no v --
f 13 M3. SIESS :
Is the work that we are talking'about 14 now in a particular branch of Standards?
15 MR. A L A R C :
Yes, it 10.
It is in the so-called 16 Transportation and Products Standards ? ranch.
This l
17 excludes, and we have not been talkin; at all today atent 18 any of the saf e;ua rd s.
This is strictly sa f e ty tatters.
19 These are the principal areas that we are verkin:
20- in.
The first is looking at the risk and environmental l
21 impacts from radio active P,=. te ri al trsns;crtatien er, to put 22 it another way, studies to determine the adequacy of the 23 existing ruler, regulations, and procedures tha t we are 24 using to protect the.public.
vill talk shout that a
~
! 25 little bit more later.
)
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1 The second area that we are into quite heavily is,'
[
2. emergency response to transportation incidents, i
3 transportation worker expecure, quality' assurance in 4 fabrication, testing, use, etc., and lastly the compability 5 of our regulations with the DOT and 1AEA requiations.
6 We have'a number of. tasks in that first. area.
The 7 assessment of the risk and environmental impacts.
t 8
NURIO 0170, of course, is not a.present project, 9 it is the environmental impact statement that dealt with the i,
10 environmental impacts cf the transportation of radioactive 11. material by air and other mcde.e.
That vas completed by in' 12 December of 1977.
13 As a follow up to'that, we started up.at about 14 that same tine with the so-called study to determine the h
15 environmental impacts of the transportation of radioactive t
i 16 materials through urban areas.
The principal verk there was 17 done by Sandia laboratories.
18 They completed their study, and it was a series of 19 NURIGs, C7c2, 07c3, and 07ac, which vare issued in the 20 summer of last year.
We are in the process now of preparing P
21 a draf t environmen tal impar t statement, which vould be a 22 generic impact statement en urban transport, which vill be 23 issued probably in the late su.9:er of this year.
24 ME. 31ESS:
On the urban study, was there a major l
1 l
25 emphasis en tha spent fuel shipment?
E
?
e
?
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%E. TALAEOs No.
'Je co ver th e wh ole gamu t, all!
2-the.way from transpertation of radionuclines throuch' spent r
3 fuel.
4 ~
%3. SIESS:
But you had all of that-in.0170, too?,
5 33, galago,
- yes, s'
6 MR. SIESS:
The big argument started when Mr.
7-Sullivan from New' York did not think tha t - s perit fuel should 8 go through New York.
Eo I thought that the urban study got.
r 9 more involved in the spent fuel and the sabora;e part.
10 33, MALAgo:
It cot involved in thoce things, but-i i
11 not to the exclusion of' the o ther thines.
Dr. Eisenherq is 12 here today, and he is the project manager.
13 YP. SIESS:
Maybe I am =ixing the two of them up.
14
'4 a s the urban study the one where'you had all thet fancy i
15 model about the vehicles and the parked cars, and the 16 micro-meteoroligiral 17 M?. MA?h:
Going up and down the.ctreet but not 18 across.
19 3E. SIESS:
I Was wrcng.
20 ME. MAiA?O:
The third study is the update of 21
'4 A S H - 12 3 9, which is a study on the transpertation of spent 22 fuel to and frca reactors.
Our originsi study wa s done back 23 in 1972.
!t was not called an environmental impact 24 statement, but it was cal 1+d an environ : ental a ssessment.
1 l
25 Tha t is being u pd a ted, and we are expecting to get a l
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contractor reportinc on that within the next tont5 or two.
2 I an afraid, unfertunately, that since the study 3 was based on the rrevious 2 dministra tion 's policy, we may 4 have to turn around and revise it quite drastically if the 5 new Administration changes the policy.
i l
6
E. SIISS:
2as that partly the result of outside 7 problems, the question of whether Duke could transfer fuel 8 fro Ocony to Maguire, er sonething?
1 9
v3. MALAEO:
Oo you mean this particular study?
l l
1 l,
10 M3. SIEss:
v es, 1
11 MR. Y.ALA?O No.
We just did this as a ma tte r of I
12 course to update a study that was nearly 10 years cid, which 13 was done by in 1972.
14 The fouth item is the shipment survey.
There was 15 extensive talk this mornin; abcut the number Of shipments 16 and types of shionents.
That was based on a shipment survey 17 done by Eattelle back in 11: 7 5.
We are in the process of 18 doin; sn extenrive update en that study.
19 There is a joint project that is sponscred by the 20 Department of Transportation, NRC, and the Oe;a r tm en t of 21 Inergy which is being carried by the Etanford Ferearc'-
22 Institute to actually upd a te that 1975 shipment survey.
23 That project is actually underway.
24 The fir t phase tf it, which i-
.0 lay Oct the i
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completed by the' end of April.
The survey will ':e completed i
2 in September of 1982.
3 XR. SIESS:
What is the end use of that?
4 MR. YALARO:
The end use of that is to use -- All' 5 of these studies that we have been doing, like TUEEG 0170 6 and the urban study,.and~ WASH-1238 update, are all. based on t
7 1975 data, and certainly a r e.*.o t as conplete a study as we' 8 intend to do nov.
So we are lookin; for data which.can be 9 used for these risk analyses.
t 10 There are a couple of other reasons for~doing this
'11 type of thing.
We have-.been asked by the International 12 Atomic-Enargy Agency to develop data for a worldwide study-i 13 on risk and environmen tal impacts, which the IAEA is to 14 carry out within the naxt couple of years.
15 In addition to that, there has been a lot of 16 pressure f cm state and local groups for this type of 17 information.
As you know that one of'the. reasons that the 18 Dep ar tm en t of Iransportation came up.With their new routing 19 rule was because a lot of states and iccal jurisdictions j
i 20 were unila terally passing rcuting require:ents which Inde it 21 nearly impossitie to ship radioactive as terials from one l
t 22 place te another.
A lot of that, it was falt, v e. n due to 23 the fset that the states just didn't tava enough inferration 24 to be able to tssess the risxs of transport ation through 25 their state, 0: through-their re;1ons.
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These are the princi al reasons for developing the 2 shipment survey.
In addition to tha t, there is a-study that:
{
3 was'done, which Don Nussbauner has already mentioned, a nd 4
that is to computerize all of the incident da ta, so that1we 5 will have a good picture of the types of accidents,-where 6 they are happening, and what the. consequences have been.
7 MR. SIESS:
How far have you gotten on that,-
8 because that I am very interested in.
9 ME. "ALA30:
This work is being done at Sandia.
10 The work just started, and we are going to get a sample 11 software program in about a month.
"e are supposed to get 12 the initial report on that thing in June of 1992.
W MR. SIESS:
It is obviously not much of a problem, 14 then, is it?
15
'd R. MALARO:
It is a problem, but the thing is is that it is not as easy a job as it see:s to pull all these 17 data.
Apparently it is squirreled away in various and 10 sundry places.
19 MR. E E:iD ER :
Events, causes and effects, is that 20 what you are esthering?
21 R.
ALABC:
No.
There are accident reports, for-22 example, that we ;et at NRC, and I think Al could probably
'ost o f the accidents 23 explain pretty much what those are.
.~
24 reports are obtained by DCT.
The problem is that the level i
25 and types of infornation that you get on these reports see:
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to vary.all' over the' place.
t 2
'J h a t we are hoping to do is to pull tcgether a 3
system which will. standardize the type of information that 4 _ you get on each of _ these incidents, so that you can get'a 5 good idea of what is' happening, and what is the extent ~
6.
damage, radiological risk, and so on, in these incidents.
7 XR. STESS:
More importantly, what you can do to 8 red uce it.
9 MR. MALAEC:
Eight.
i 10 MR. SIESS:
Otherwise, it is not worth '<nowing.
11 3R. BENDER:
I will qualify it by.ssyinc,'whether 12 it is necessary.
13 MR. MALARC:
That is the principal reason, raally, 14 for a lot of these studiec._ We have reg ula tions on the 15 books and so does DOT, and a lot of this is an effort to 16 find out.whether we need new ones, whether we need to modify F
17 the ones ve have cet.
18 ME. MALAEC:
The next item ic the package surface 19 contanination study.
This is actually based, I believe, on 20 a request by the GAC.to lo.ok at the possibility of reducing i
21 package surface contamination limit: to as icv as reasonably 22 achievable.
Essentially, what we are dcing is a small 23 contractor. study to find out what, if any, problems really-I 24 exist in that area.
25 The re st of the programs I put there for the sake I
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2 3R. SIESS:
Didn't hUEIG 0170 assume certain 3. surf ace contaminations and looked st: risks from transporting 4 these things?
5 MR. MALARCa' Yes.
i 6
- 53. SIESS:
I recall'that it'did notc show very 7 much contribution-to risk.
~
'8
- 53. MALARC:
No.
Don, perhaps you can' address
~
9 that.better than I can.
10 The real questien is what the real contamination 11 limits are out in the' field, and whether or not there.were 12 public health problems, whether we should_take steps to j
i 13 red uce them as low a reasonably achievable.
?
14 "E.
SIISS:
You mea." if people are ending up with:
15 i "1111:em, and you are permitting 10, you v4
'cVer it to i
16 1.
17 VE. "ALA?O Yes.
18 I a juct going to skip thr0 ugh the rest of 19 these.
The next of these is the surveillance program that 20 Don Nussbaumer has already talked about, and the other three 21 are items that are handled by 5%55, which I think we vent 22 through at the last meeting.
23 1R. SIE35:
'J h a t is t h e h' A SF - 14 ?
i 24 MR. MALAEO:
That is the update that deal with 25 updating th e 5-3 ticket.
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MR. SIESS:
Okay.
2
- 23. ZALAEOs I think the SLA study you talked 3 about th'is morning.
4
- 33. SIESS:
Yes, we know.about that.
5 M3. MARK:. Everyone is aware of occasions when low 6 level waste got public'attentien because of improper 7
packacing, or something.
Hov is it with the medical i
- t 8 isotopes shipments, are there instances where'the levels are 9 far beyond acceptable values?
10
.i R..5 ALAR 0' You mean.the radiation levels of the 11 packages?
12 ME. MA?K:
A package on a plane or a package on a 13 truck, whica are supposed to be so many E per hour at a l
14 meter, but in fact turn cut te depart from that.
i 15 MP.
.M A L A 3 0 :
I honestly don't know.
16 A1, : think you vculd be in a better' position to 17 answer.
The bas: source of information en 1
l 19 the isctepe shipments from ~ hospitals and to hespitals is 20 probably in the summary raports of the state surveillance
?
21 contracts.
If there is non-cce pliance, I dcn't think that 1
22 it has teen showing real haavy trends.
Sometimes the 23 radiation level on the package is mor6 Or less than is i
24 indicated on the label.
- seems to be goin; teth ways.
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have been violati ns involving radia tion ' levels on the 2 vehicle exceeding limits, and there have been civil penalty 3
cases.
- cst of those involved reactor vaste, and some 4 brokers who pick up' waste fro: institutions and hospitals.
5 You have ncn-compliance on radiation levels in 6 each area, but it has not been'a large problem.
.Most of the 7 stuff involves sismarking, mislabeling,' shipping. paper 8 violations, and tha t kind of thing.
9 XE. MALA 30:
The next -ite is emergency response.
10 As I understand it, th e initial im petus for this was the i
t 11 so-called yellow-cake incident that we were discussing this 12 morning.
Apparently tack in 1977, when this incident 13 happened, where a truck of yellow-cake which turned over out 14 in Colorado, there was a interagency study group which cane 15 out with recommendations in July of last year, a nd one of 16 the recon =endations was that there te ex tensive verk to t
17 provide guidance to the sta te a nd local ;overn=ents on an 18 enercency response to transports 100 accidents.
I 19 XE. SIISS:
Tranrp0rtation accidents in ;eneral, l
I 20 or involving radioactive naterials.
l l
1 21
- v. E. %ALAEO:
Invclving radioactive materialr.
i i
22 ME. SIE55:
There is an equally crest need in J
l 23 transportation accidents involvinc ether
".a ardets i
l 24 materials.
I was wonderin; whether they were.urping these 25 together in the. state plans, like we are tryin to do in ALDERSON REPCRTING COMPANY,INC, 400 VIRG.NI A AVE., S.W., W ASHINGTON, 0.0. 20024 (202) 554 2345 1
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terms-cf reactor emergencies, the FEMA type.of' stuff.
2 MR. MALAE04 FEMA is involved with this thing.
,4, 3 The four agencie actually involved in'this business are l!PC,
j 5
MR. MARK:
We learned this craing that 1
6 yellow-cake is not really.a radiological haza rd.
7 MR.
Y. ALAR 0:
That is true, but it is a-8 psychological haza rd if' nothing else.
I 9
5R. SIESS :
What I am getting at, there_are so t
10 many hazardous things-being. transported.
I forget what the 11 national average is for railrced derailments involving 12 hazardous aaterials, I forget if it is one a day or 10 a-l 13 day.
It is about one a week in my neightcrhood that makes 14 my local pa per, and every one is within the city. limits.
15 ME. 9ENCEE:
It is the same way where I live.
16 MR. SIESS4 I don 't see why the state people 17 shouldn't be trained to have a transportation accident 18 involving hazardous materials, and radioactivity p ro b a bl y is 19 one of the easiest enes because it doesn't involve t a n '<. - c a r s
+
i 20 burning, and things of that sort.
3 i
4 21
?
A 1 A R C :
I can't answer that one.
22 Don, you are more steeped into the hirtery of this 23 than I am.
24
- 33. MCPKINS: In plannin; the' efforts that we have 25 underway with resp +ct tc the radioaction safety programs, it r
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is certainly recognized that aany cf the parts of an 2 effective radiation emergency response program are shared 3 with any other hazardous ma terial.
"e recognize that the 4 money ve are spending is not being used only for radicactive 5 materiale, but vill also be extended, in all probability, to 6 other ha zardous ma terials.
7 We are a little limited in what we can de in our 8 operation, but once you e stablish good communications, 9 transp6rtations, and these kinds of rystems, they are common 10 to the response f or all hazardcus matecials.
11 M P.. EIISS:
If you try to sell this to the states, 12 they don 't have one radiation accident in 20 years, a.id tney 13 have these other things happening every week.
Their 14 alertness is at a much higher level on general 15 transportation accidents.
16 I admit that there are scme special things with 17 respect to radioactivity, lut some of these other things you 18 need a chenist to knov vhether these two tank-cars are 19 dangercus because they ar=
.e x t to'each other, 0 whetrer 20 this one is burning and tha t one ir likely te exp10de.
21 There are the same kind of uncertainties, the same kinds of 22 approaches needed for both of ther.
23
- think it is nice to do it for radioactive 24 materials, but ir most states the people are goin: to ;et 25 avfully rusty, and t he. vill ha ve their perconnel turn over ALDERSON AEPCRT:NG COMP ANY. INC.
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three times before they have ancther yellow-cake spill or 2 something like taat.
3 MR. GREL10:
'4 h a r e there is emergency response 4 planning going on in the states, they tend to be starting 5 with the general realm of hazardous materials.
A lot of 6
them become aware of the radiclogical harards and fit that 7 in.
8 In railroad accid ents, emergency response planning 9
at the state level is concentr2ted on hazardous ma terials in 10 general.
11 MR. SIISS.
It is not furt railroads, because 12 trucks turn over, too, but there is not as.?uch of that as 13 there is railroadr.
14
.M E. GRE110:
The problem is that thare tre so many 15 agencies involved.
16 MR. SIEES:
Most states have disastar 17 org aniza tions who work oc t ran t;c rta tion accid ents, Ours 18 does, and 1ccelly the same one that verries about tornadoes, 19 worries about derailments.
20 ME. MA1APO:
In addition to that, we are aire 21 looking at the ;cssibility Of applyin; some regulations on 22 shippers, so that they wculd provide ra rtain types of 23 information tc the states On these thin;s.
I'. i s is juct 24 another thi n g that we are lookinc int 0.
25 The last itca th-re --
ALCERSON REPcRTING COMPANY. iNC.
400 VIRGINIA AVE 4.W., WASHINGTON. D.C. 20024 1202) 554 2345
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215.
1 "E.
SIESS:
Oces the carrier have to have a 2 - manifest that show:: what he has got?
3
,3 3, vALARC ves.
4 Y.E.'SIESS:
What.about a-broker, does he have to 5 keep a record on-his truck-of what he has got on it.
6 vE. MC? KINS:
He would.make out an additional 7 s hi pping paper, with the original shipping papers attached t 8
it, ; believe.
A consolida ted shipping paper for his E
9 consolidated chipment.
l 10 13..SIESS:
These guys that run these little vans 11 picking up r a dio-p h a rm ac e ut ical s, do they have to carry 8
12 shipping papers or a manifest?
- v...
- u.. C D Y...".i c.-
Ves.
f 13 s
i 14 "R.
SISSS:
You are not so much concerned what is 15 in th e p ack a g es, but I guess you veuld like te knew that, 16 toe.
Eut if P.e has SC packages on there, a nd. he leses two, 17 does he know?
18
- 12. FC,? KINS:
Es knows how. P. n y packagar he has.
19 He has paperwcrk t h'a t would indicate that.
3 20 ZA. SISSS:
When thet airplane crashes with a lead 21 of pharmaceuticals,,can somebcdy tell what is en it?
22 Y. E. E0? KINS:
f you can find the paperwork.
23 M?. 5:555:
"ould it be on the airplana?
24 S?. HC?K!NS:
Th er e would 'ce paperwork on the 25 airplane, with copies of it elsewhere.
.[
P e
I f
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- ALDERSON PEPoRTING COMP ANY, INC, 400 VIRGINIA AVE., $.'N, WASHINGTON, D.C. 20024(202) 554 2345
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!R. SIESS:- Until recently, We'have seen railroad 2 - derailments where you had te wire New York to find out what 3 is in the car..
They might have had a label on; the car, but 4 after the fire nobody could read it.
5 Now the railroad s ha ve put tha t informatien on 6.
computers, and are providing-it to the division 7 superintendents, or something, so that th e people know what 8 is on.those'tre. ins, and they don't have to wait.,an hour to
~
9 find out what is in that car.
10-You say that you are working on that, b u t.' m y point 11 is, why a r e n '. t they doing it now?
12 MR. MALAECs Maybe I mislec you.
The idea was 13 actually to require the shipper to provide informa tion ahead 14 of time en routing, and whatnet, so that the state and local 15 people would be abla to prepare any kind of emergency 16 res ponse pla ns for particula r types of ship:ents.
17 MR. SIESS:
So for every shipment, he notifies the 18 state police Oo that they can be prepared to move if they 19 had an accident.
i i
20 hE. *ALAEC:
No, not every shipment.
We are I
21 talking about la.rper shipments.
This last item came from a i
22 pertition that has asked us to put a whole lot cf 23 requirements on th e shipper, and I will cive you an idea cf 24 What they are.
Cne is that the shipper make Out a extansive 25 eme rgency response plan, and be prepared to step in in case 1
1 F
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2 the shipper have financial responsihility-in emergency
-3 response.' That'is a petition we have in-house now to try 4 and an ver.
5
'33. SIISS:
-can understand that..you need to 6 answer that,. hut I don't know'that that petition is really 7 concerned with safety or..rather just harrissment.
8 -
You said that you wouldn't do tha t' for every-9 shi pm e n t.
'4 h a t kind of shipments woul'd you -do it for?
i 10 M2. MALA 30:- Eor shipments, for example, like 11 spent fuel.
i 12 XR. SIESS:
The government already has to be 13 notified of every spen t fuel shipment now, and of the 14 routing.
15 da. f.ALARc As a matter of fact, that type of 16 thing that we have just done was based --
17 ME. SIESSs He doesn't have to do anythin; about 18 it, if he doesn 't want to.
'*e doern't have to tell I
19 anybody.
rven if it is not an agreement stater he deern't
[
20 have to tell anybody.
i I
21 tE. NUSSSA*J.1EE:
The law requires that the 22 Governor he notified.
~4 hat he does with that within the I
23 state is up to him.
I 24
- 12. SHA??I??.
!s that on the' books new, or is i
p 25 that a proposal?
J 1
ALCERSoN AEPoATING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTCN. 0.C. 20024 (202) 554 2345 u
219 1-
E. ' N USSE A UM EE :
There is;a[ law that says'the NEC' 2 must develo p. regu'la tions.
3 MR. SIESS:
I.think that it is a. proposed rule..
l 4
MR. NUSSBAUMER:
We have a proposed rule'out for-
.]
5 comment on.that.
J 6
- ME. SIESS:
It-assumes that the' Governor is n'ot.a
~
7 saboteur.
8 hs. y,A1Aso:
This proposed rule, actually, work 9 was started'on this.before that lav was passet That law 10 actually puts into effect come of the things we intend to do 11-with this.
12 The next item is the transpert-vorker exposure, l
13 and Don had mentioned this earlier.
The problem with the I
14 expocure of transport workers actually came out of the DOT 15 state surveillance program that Don was talking about.
The l
16 problem deals vita not only the drivers, vans, and w ha t -not,
l
?
17 but alco the f reigh tha ndlers, f or example, in freign i
18 facilities that handle a lot of ship.?ents of medical i
19 r a d io -ir o t o p e s.
[
20 As a result of the informa tion that we have h
21 gotten, we have let a small contract to get some mere i
r 22 information on this thing.
The centract was given to~the 23 Eeynolds Company, and the contracter re;crt vill be done at 24 the end of April of this year.
Based on that, ve vill make l
25 a determina tion as to whether er not we need to de sorething I
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concerning regulstions.
2 MR. 5I735:
% hat kind _'of doses' vill-these people
~
t 3 get?
4
.5 R. MALAR 0:
A radiation worker can get up te 5.--'
5 MR. SIESS:
No, these people, the transport j
-6 workers who are not.radia tion workers.-
t 7
MR. MALARO:
As members'of the general.puolic,
(
8 they should be restricted to doses of half-rem or less.
l
~
t 9
MR. SIESS:
I know..
10 MR. A L A R C :
There are indications that they have f
11 been gettin; up to three times that much, er two-and-a-half-12 rems.
13 MR. SIESS:
Two-and-a-half, some of us get almost 14 that much flying to meetings, don't we.
15
$3. PIE EP :
Yes.
+
16 MR. LANGAAR:
Airplane pilots ge quite a bit.
17 XR. SIFSS:
It depends on what you get it frem, 18 then.
19
( '.a u g h t e r. )
20 YR. MALAR 0:
The next itan is quality assurance.
r 21 The rules were amended, as you know, back in 1977, and they 22 had appendices for OA.
Whtt va have reen doing is following 23 up with specific Ouidance on ;uality assursace for the 24 manufacture, testing, use, repair, etc., cf a number of 25 shipping containers.
r ALDERSON REPORTING COMPANY,INC.
i 400 VIRGINIA AVE., S/W., W ASHINGTCN. D.C. 20024 (202) 554 2345
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There are two guidec being prepared right now.
2 One is fer spent fuel high level vaste and plutonium, and 3
the second for normal and special form radioactive material 4
packages.
5 MR. SENDE?:
For fabrication of those packages?
6 YR. MALASO:
Not only the f a b riEa tion, but the 7 operation, use, and repair.
Eoth of those guides vill be 8 published as draft guides within the next two months.
9 The next item, of course, is the CCT/IAEA 10 compability, and I don't want to go into that.
Don can give 11 you scme idea of what we ',wve done in that area.
12 ME. E!EES:
I don't think that relates really 13 totally to anythin; that we are goin; to be looking at 14 here.
It is conceivable that 29 may end up vanting to look 15-at the whole picture, inc29. ding the parts that NFC is not 16 in.
17 MF. IU;ANS:
NEC is dcing something.
s 18 JE. 5A;AEC:
The ene thing we are dcing, we are 19 gettinc ready to ao out with a revision to Tart 71 whirh 20 vill ake it more competitle wi th the IAEA regulations.
OCT 21 vill simultaneously go out and do a rulemaking.
22
- f. E. CIISE:
This is cemething va vill '. ave to 23 decide on sithin the scope of our review.
If we are going 24 to reviev the criteria, then, yes, we vill probably want to 25 look at that more.
If we are going te 11.91t curselves to 1
1 1
1 ALCERSoN AEPoRTING COMPANY. INC.
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1 400 VIRGINIA AVE. S.W., W ASHINGTON. D.C. 20024 (202) 554 2345 l
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-I 222 1
the degree to which the, criteria in f orce is complied with, t
2 we would not be interested -in where the criteria came f rom.
3 I think that we should hold off amore detailed.
t
'4' discussion of that until we decide which way we are going; 5
M R. A L A R O : lI am not sure that you want to no 6 through ' the miccellaneous items either.
7 MR.. SIESS :
'4 e will'be lookin; st..the revision to.
.8 Part 71 I will be looking at.it mainly f or.its i
9 scrutibility, and not so much for the contant.
f 10 MR. EEFDEF:
The one thing we don 't 'vant to 11 overlock is-if there are constraints put on by either ?CT'or 12 IAEA in th e packaging problem, an? that we know what.they 13 are.
Maybe there aren't any.
14 YR. MALAR 0:
If you are interested, Don has been t
15 workina on that, and he probably could give you the 16 information in five minutes.
17 MR. SIESS:
We heard a little bit thic morning 18 about how the Iart 71 revision is being made to relate to 19 IAEA standards.
That is what we heard, icn't it?
20 MR. MCPXINS:
Yes.
21 MR. SIESS:
The ?CT part is that TCT has to change 22 those, because if you change the beundary, it has to be a i
23 mutually a; read boundary.
So : think we have ;ot som+
24 background on that.
25 The ?CT routing rule --
1 l
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33..ZALARC.
That is part'Cf the transportation 2.
role, and I have put it in there just for:the sake-of 3 completeness because ve ha ve t'een provid'ing DCT vith 4-technical assistance in developing that.
5.
- 33. SIESS:
This is on the question.of going
~
6 around cities.
Did they preemp the' city's.right'to
- 7. -
MR. MALAEOs As I understand it, the DOT,' cr at 8 least the Eederal rule preempts the ctate rule.
When it 9-came to a court case, it turned out that you coul?.n't have.
10 preemption without a rule.
Since the OCT didn't have-one,-
5 11 they needed to.put cne'en the tooks.
12' (General laughter.)
13 YP. EEN?EP:
But you ". ave requirements ' tha t are-14 more restrictive than COT's requirements?
15 5E. YALAEO:
Again,' you are getting into a legal 16 a rg um e n t.
As ! understand it, there are areas where DOT and 17 NRC are both responsible for rigulating the trsnaportation 18 of radioactive ma terials.
In order t keep frcr overlapping 19 the rules, ve have a memorandur of.understandin;, which we l
e 20 have already talked about.
21 If we vere goinc to apply rules in this area, 22 obviously we vould have :, discuss it with DOT, and perhaps 23 to amend tn e ?.ecorandum of unierstanding.
24
- v. E. SIISS:
I h=ve gotten the feeling this 25 morning, and ! vould like te have it confirmed or denied, t
1 ALDERSON AEPORTING COMPANY, INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C 20024 (202) 554 2345
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-1 that the level of cooperation between NRC snd DCT is very 2 high, and very smooth.
Is tha t right?
r 3
MR., XALAR0s. I-have been in this-business for a 4 very short time.
5 Don, you can probably answer.that.
6 33, HopKISS:
Some years ago, that'was the case.
7 In recent years that has not been so much-the case, as the 8.saf eguards people a re intruding into.the transportation 9 ' 's y s ten, and ara re g ula ting carriers, providing routing 10 requirements.
Cur safeguar.ds people are also providing 11 rou ting requirements.
12 It takes a lot of coordination to get these kind 13 of things very compatible, and enough coordination has not 14 been done.
There has been rone.
15 MR. SIISS:
What about on safety?
16 YR. HOPXINS:
Cn safety, we used to have a lot of 17 cooperation.
The DOT representati'te, when it was 3.1 Grello, 18 was very cooperative.
In more recent years, with respect to 19 the reuting rule, for exam;1e, they put their final rule l
20 into effect without werd one to NEC.
[
In the last four years --
22 1R. HOPXINS:
In the last two yea rs.
23 ZR. SIESS:
--they have changed.
24 "R.
MALARC:
The only one : vould mention in the 25 miscellaneous business is that we are cettin ready to put I
ALDER $oN AEPcATING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 out-a reculation which viil essentially put:into the rule 2 the' Scheuer aiendment, which ve:have alread y in posed by -
3 putting conditions on the licensees.
'4 MR. SIESS:
The second item would seem tc be a 5
fruitful source of information on,non-compliances.
6 MR. MALAR 0 Yes, it vill', as'a-matter'-of fact.
7 Tha t particular item came u p, I think prima ril'y because we 8 had assumed that package monitorin; on receipt was already 9 covered under the rules.
As it turned out,: the regulation
. 10 is written in such a way.that we needed to put a new section-11 in that required it.
12
'i h a t the new rule vould do is require the receiver 13
'o f the material to monitor within a certain a: cunt of time 14 after receipt, rather than possibly leaving the package 15 hanging around for a while.
i 16 ME. SIESS:
This is prinarily surface 17 ' con tamination ?
18 ME. MALARC:
Surface contamination, and external i
19 radiation levels.
20 MR. SIESS:
'4h a t about water, the liquids leakin; 21 out.
22 M?. MALAEC:
Yes.
23 Y.?. SISSS:
They see: to have been dein: a pretty 24 good job on that lately.
They have been disecveri.ng a let 25 thet have leaked.
ALCERSON REPCRT!NG COMPANY. NC.
400 VIRGINIA AVE., S W., WASHINGTON, D.C. 20024 (202) 554 2345
226 1
lY R.
MALA?C The incpections at the burial 2 grounds, which is'where they found most of these things,.-are 3 ~ pretty extensive now.
4 MR. SIESS.
This monitering on receipt would apply 5 - to hospitals that receive ;harmaceuticals?
6 MR. MALAR 0:
It would apply to any licensee 7. receiving radioactive materials.-
8
.5R. SIESS:.That third l item, 1: vas mentioned 9 earlier that there has been a' lot ~of mislabeling.
10 YR. MALAR 0':
That would not ap' ply'to labeling, but 11-it would as a guide for actually sessuring the radia tien 12 levels on the external surfaces of the packages.
There have 13 been'a lot of problems with this type of thing.
As you 14 know, the surface radiation level doesn't mean much if you 15 take a package with
- a. chamber that large.
16 "e are going to prepare some sort of a guide
't o 17 give some sort of an idea of how to carry cut sc e of these
.18 radiation readings.
19
- 12. SITSS:
! Was vendering if sos.e'of this 20 mislabelin; wasn't due to the fact that the people that 21 labeled had used one sert of measurenant, and the people 22 that checked it used anothe r sort.
23
R. MALARC It could well be.
24
- R.
GRE110:
This goes into the enaracteristics Of 25 the instrument, and the detector distance Of th e pr be.
ALDERSON REPORTING OcMPANY,iNC, 400 VIRGINIA AVE S.W.. WASHINGTON O.C. 200244202) 554 2345
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This will all contribute to the variationc.
Fadiceraphers 2 make it a point of dif f eren ce.. technique and instruments.
3
- 33. SIESS:
The standard of measurement might not 4 improve the safety in any way, but it would reduce the 5 non -com plia n ce.
6 MR. CEELLC:
There is a real danger when the parts 7 are co m plica te d, too.
8 MP. SIESS:
Are there any other questions, 9 gentlemen?
10 Let me ask a couple of questions on the NU?EG 11 0170.
That evaluates riske from various modes, and various 12 kinds cf materials?
It evaluted risks for normal trans; ort, 13 and risk from a.ccidents.
14 As I recall, ths risks from accidents were very, 15 very low, sirply because the probability ic very low.
16 Having an accident, and the probability of the packages 17 designed the way they are desi ned for surviving is pretty 18 high.
19 Can ycu break out of that study what proportion of 20 the risk could be attributed to th? kinds Of packages that 21 the Transportation Certification Erancr ic interested in, 22 that is Ty;e ? and Type A ficcile?
23
.". R. 'O? KINS:
We can trsak it out by fuel cycle, 24 which is certainly one of the areas that the rertification t
25 is active in.
We can break it out by industrial packsces, a ALCER$cN REFoRTING COMPANY, :NC, 400 VIRGINIA AVE. S/N., WASHINGTON. C C 20024 (202) 5!4 2245
228 1
lot of which are the radiography type packager which ve do 2 certify.
3
.Y E. SITSS:
They are all Ty;e 3, then.
Some of 4 that would be 1SA?
5 NE. FC F FI.N S :
There is more in it than is involved 6
in Chuck's reviews.
But we caly treak it out fcur ways:
7 The radio-pharmaceutical stuff; the industrial stuff; fuel 8 cicle stuf f ; and Waste.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDERSCN REPORTING COMP ANY, !NC, 400 VIRG ANIA AVI., S.W., WASHINGTON O C. 20024 (202) 554 2345 Y
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MP. FISSS:
Sew as I recall the 2 radiopharmaceutical is the Ia]c: portion of the risk from 3 normal transportation?
4
't R. FOPKINS:
That 1.s correct.
5
- 53. SISSS:
Those are the type " A" and exempts, 6 aren't they?
7 E. MCPKINS:
That is correct.
8 M3. SISSS:
What was left which would include some 9 type "A"
probably, but mostly would he type "3",
what 10 proportion of total risk was that?
11 9?. ECPXINS:
Secething more t'an half of the risk 12 war attributable to th e r a fi:ph arm aceutical and medical 13 industry.
Fuel cycle and industrial were about on a par and 14 I think vaste was something less.
15
.. o..
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"a h a t.
- e... 3.. + 4 o..
.e
'.o+.+ -..
'.a..e
.is 1
16 associated with live accidents?
17 AR. HOPVINS:
Aheut one percent of the normal 18 risks.
19 MR. 2!S3St This is the protability y0u vouid put n0 in.o
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and type "A"
ficsile packages are small both 25 in abselute and in relative t+r s.
ALOERSON AEPCRTING COkiPANY :NC.
400 vlRGINIA AVE., S W., WASHINGTON.1C. 20024 (202) 554 2345
229 1
MR. ECPKINS:
The risks from type "A"
and type "3"
2 packages?
3 MR. SIESF:
Type "A"
fissile packages.
4 MR. HOPKINS:
The normal risk when you get into 5 accident risks is the type packages because of their "C"
6 larcer quantities take up a lar;er share than they do for 7
tha normal accident.
8 d?. SIESS:
Of the accidents.
9
- 53. F0PKINS:
Yes, Of the accidents.
10 MR. SIESS:
Put they still are very sT.all ecmpared 11 to the norm al.
12
- R.
HOPKISS:
I t elle ve we have a summary slide 13 hare.
14 MR. SIISS:
Put it on.
If we went to get into 15 spent fuel packages and sabotace then there are scme fairly 16 hairy scenarios, alth0c;h ! understand sc:e of the 17 experiaantal work that has been done cuggests that they were 18 hairier than necessa ry.
They were assuminc p r e t t;. large 19 pro;crtions of the fission ;r:d uc ts w re released.
20 (Slide.)
21 MR. MOPKINS:
Th-first colu:S just describes the 22 type of packs;e we are talkin; about and the recend column 23 number of the ;ackages ;er year, th e third is the curies in 24 the packager.
There is where the first ti; dictinction 1
25 comes in.
The fuel cycle packagas have twc crdc s Of i
l ALDERSON REPcRTING COMPANY, :NC.
400 VIRGINIA AVE., S.W.. N ASH ANGTON, O C. 20024 (202) 554 2345
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magnitude of a number of curies than the Others.
2 EE. IIISS:
" Limited" means what?
3 MR.
- OPKINS:
Those are the exerpt type packages d
4 we were talking about this morning.
5 Ihe TI per year are reasonably even and the 6 kilometers per year aren't significantly different.
The LCF 7 for medical a re
.6 or 50 percent of the total.
a
- v..o..
e A _ e. e
_ r "4....
is.-r. a,ai.9 w..
9 MR. HOPKINS:
Latent ca nre r f a talities.
- t is the 10 only thing we compare.
It is about the same number for 11 gonetic deaths.
12
- 53. SIISE:
Accidents are within two crders of 13 macnitude down.
14
- 23. "0?KINT:
The industrial LCF for nor7al 15 transport are 20 percent and f uel cycle is enly nine 16 percent.
It is not until you et into the accident 17 co n t rib u tio n that they are about equal.
18 ME. SIISE:
The S. i ; fum; in 65 on fuel cycla is 19 assuming a lot more spent fuel?
20 MR. HOPKINS:
Yes, there is a lot mere spent fuel.
21
- 12. EIIES:
Theoretically.
- assume at that time 22 there would he.
23 M3. E0? KINE:
Th+:e would ha a lot cre reactt:3 24 generally se would assume.
25
- 12. ?!ISS:
We don't have that, do we?
I ALDERSON PEPORTING COMPANY, INO.
l 400 VIRGINIA AVE., S/N. WASHINGTCN. O C. 20024 (202) 554 2345 j
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- 32. HOPKINS:
It is in 'UEEG 0171.
2 M3. SISSS:
How do we use that type or what do we 3
use it for?
4 ME. HOPKINS:
It shows the contribution to risk, 5
both normal risk and accident risk f ree dif ferent categories 6 of material, limited versus medical.
7 MR. SIESS:
The LCF is on the proposed population, 8 I don't remember what you used for that.
9 3R. E0PKI;S:
Twenty million pecple I think were 10 considered the exposed population.
These r es'u lt s are of 11 course a function of the modeling that we prescribe;d for.
12 The modeling was based on what we knew from the man studies 13 tha t we have undertaken since 1972, 14 MR. SIESS:
But your accident probabilities for 15 some of those are pretty darn good because yca have got a 16 fairly good s ta tistical ba re.
I think the accidant 17 probabilities for a fuel cycle have pretty large 18 uncertainties en th em.
I for;et wha t your acdel vas for 19 that.
20
3. FCPKINS:
As you say, the accident statistics 21 we took from normal truck a ccid e n t statistics and that would 22 be pretty good.
23 XE. FIFSS:
That is right.
24 Y?. FCPX!NS:
It ir just the modeling thwt :ou
?5 apply to that to ;c th e rest cf tha way.
It is questionarla
. ALDER $cN REPcRTING COMPANY, INC, 400 VI AGINI A AVE., S.W.. W ASHINGToN. O C. 20024 (2J2) 554 2345
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1 1
but ve used pretty conservative models.
j 2
MR. BENDER:
I think it_is that term " pretty-3 conservative models" that makes'it hard to kncv how to use 4 that table because that is an imprecise term and'it could 5 -mean you overstated th e answer. -
6
- 33. SIESEs Conservative means they overstated it.
7 I think.
You see, these were. all fire intensities and 8 durations and things like.
I 9
TR. ZUDANS:
By conservative or something'do they i
I 10 mean the high rates'as computed are overstated?
11-MR. FOPKINS:
If they are very f ar of f they'are 12 too high, 1
13 MR. SHAppERT:
Old the limited mean the type of 14 shipment?
I 15 f3. HOPXINS:
Except the exemptions.
Icu can see 16 the number of curies in the limited shipments is very s:all.
17
%F. S!?SS:
The medical stuff is very small.
18 XE. HO? KINS:
Some :f it is.
'ost cf it is type 19 "A"
packa;es.
't 20 MR. 3ENDEE:
Let's ;o tsek to the next to the last 4
d 21 column which is probable events.
l 22
- 72. SIISS:
The next to the last column, there are 23 two separate columns, the normal and the accident.
1 1
24
- 35. EES?IE:
W il, ! quess I don't really know
]
1 25 What one I an icitin; at.
Which one is ;cverninc?
Thst is ALDERSoN REPCRTiNG COMP ANY, INO, 400 VIRGINIA AVE S.W., W ASHiNGTON, D.C 20024 m2) 554 2345
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1 what I am trying to get at.
2 5E. SIESS:
These notices come frem ner al 3 operations.
4 "E.
HOPKINS:
These are the latent cancer 5 fatalities attributed to normal operations in the absence of 6 accidents.
Over here are the latent cancer fatalities 7
attributable to transportation accidents involvinc the same 8 packages.
9 MR. SENDER:
I guess what I am tryinc to say is 10 that when you are lo cking at the regulations, what 11 regulations are y:u lookin: for.
12 3p, SIIss
,tacka ec for normal transport have to 13 meet certain ctandards.
They are all identified and the I
l i
i 1
(
14 Transportation Certification ::anch certifies that they have i
15 to meet accident conditions.
16 U..
EENPER:
1 dcn't think ! am maki".;
.y point 17 but I will try one mora time to see if I can.
If I were 18 loo king at the re gulations, and what : as trying to 19 establish is whether the re gula tit ns are ad e qua t e te assure 20 that the arcidents are limited to some rate.
There is a 21 assumption in that next to the last table that we know what 22 the rate ic.
That is based on ex;=rience er it enn be based 23 upon ---
24
'# ?. S:ESS:
In trans:crta.icn by truck line they 25 took just trurk accidents per -ile.
ALCERSoN REPCRTING COMPANY, INC.
400 VIRGINI A AVE.. S.W., N ASHINGTCN. O C 20024 (202) 554 2345
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M3. 3ENDEE:- That isonly part of it.
We.have to 2 think about' what-the dispersal is if you ha ve an accident.
if 3
3R. SIESS:
They had some figures.on th'e fire and
'l s
f 4-how..long the fire could last and het ' it could be.
5.
- 52. PENDEP:. I guess all L a rt scying is that I am f
6 no t.. s.ure ! wo uld kno w wha t to do with the table after I.
7 have' looked at.it bayond caying there..is a set of numbdrs.
'i 8
MP,.
HO? KINS:
Well,.you would have to icok at the-l 9 report and see what the model is.
Thon if you disagree'with'
{
10 the model then you-disagree with: the'results, but'you'can c
11 look at the model and vary it however you want to modify the 12 results.
13 M3. SIESS:
You.can look at this and say : hat 'if i
14 the packages were a hundred times less' resistant to-i i
15 accidents you still would only get acrldent risks comparable
[
s.
16 to those from normal operation.
17
- 13. PENDER:
I just think about what seemed like a 7
18 dominant risk before where the cover.vas inproperly put on 1.
19 the packag?s.
20 53.'EIESS:
'f ell, in the nor al operation: you are 21 going to get some doses.
It is note likely to core a pa rt in i
22 en accident.
'! c v you are taking the probability t h =. : if the 23 ca; is not on there is the potential probability of an 24 accident.
It is '2nlikely that leavin: the ca; off is going
.t 25 to cause an. accident..
s ALDERSoN AEPoRTING OcMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON, C.C. 20024 (202) 554 2345
235 1
.Y E. EENDEE:
I don't know what the definition of 2 an accident is and we are in trouble en tha t.
3 33, gopKINS:
Well, the transportation accident is 4 what we' are talkin; about where a vehicle cellides with i
5 something or another vehicle.
6 "E.
EENDEE:
So it is not accident invcivina but 7 misuse of the cask or something.
8 n?, g:ESS:
Those would end up under normal 9 transport.
10 ME. EEVDES:
Okay.
I didn't understand.
11 YE. SIESS:
They will have a.?aked effcet.
12 How mucn of a normal tran;crt base 10 attributed 13 to, let's say, improper packaging under normal use?
14 hE. E0? KINS:
We locked at that in the 'UEEG 0170 15 document and described it frc what we knew about it at that 16 time and decided that it was not significant rorrared to the 17 normal ex;0sures.
With the urban study, if I understan d 18 correctly, th+y looked at it again and used a different 19 model and decided it was shout com p a ra ble, that you veuld 20 get as much risk from quality errors and human errors ss you 21 do frem normal operation.
22 ME. 5:ESS:
That is just a f raction of what you 23 would get from just normal ex;0sure.
24 "E.
"CPK NS:
I am corry.
fay that s; tin.
25
?. E. SIE?S4 The i ni ti al 0;ersticas Only contribute ALOERSON REPcRTING COMP ANY, INC, 400 VIRG;NIA AVE., S W. W ASHINGToN. O C. 20024 (202) 554 2345
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about one percent or so.
2
- 33. E:sg33Eaca - ' h11, the.other thing in'the urban 3 study is tha t it appea rs. that the. accident risk'is hi;her
~
~
4 than the normal risk.
5 M3..SIESS:
Mov did you get' te that?
6 Ma. sgAp?ERT:
Tha t is three orders of magnitude, 7 isa't it?-
8 YR. 3ENDtE I's that w'it h sabotage?.
9 MR. EISENGERG:
No, it is something else.
10
.ZR.
3ENDEE:
Well, now did you get that far 11 -dif f e rent from this?.
i 12 3R. EISENGEEG:
Well, remember it is just' I
13' transportationin cities.
In cities ! believe the 14 combination of the higher population and.the fact that the 15 buildings,-for example, do a good job ci shieldin;Lall the i
16 people in buildings'from the normal trans;crt but they don't 17 do a very good job of shl=1 ding people fron inhalation or 18 from material dep0 sited on the inside of the buildings.
19 Those kinds of factors come into play and tilt the balance.
20 XE. S!ESS:
So if this has s total in it, and if !
l 21 took out tne urban transportation, it would be about 50-5C 22 and the non-urban transportation would be w eig h te?. Very 23 strongly toward the normal transport.
24 ME. EISENGE2G:
It seats to be tact way.
25
- 12. S!ESS:
Now, you teck the whole urban U.
S.
)
c ALOER$0N AEPORTING OCMP ANY fNC, 400 VIRGINIA AVE,. S.W. WASHINGTON, O C. 20024 (202) 554 2345 l
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when ycu did your study, I ;uecs, didn't you?
2
??. EISETEEEG:
We cencentrated on New York but we 3 obtained estima tes f rom 2C other large cities to try to get 4
a generic f eel for what a city was looking for.
5
- 33. gigsS4 Looking at this, this is total U.
S.,
8 1975, and 1CF normal is 1.19.
How much of that veuld be 7 urban?
The urban a cciden t dose can't get abcVe what it is 8
for the total of the country.
9 MR. IISENBEFG4 Wait a Pinute now.
10 MR. SIESS:
Oce: the table in clud e urbar: and rural?
11 MR. I!5ENFIFO:
Eight, but it ir ve ry htrd to 12 compare with the urban stud y becaure ve are really usin; a 13 different set of acdels.
I am not sure that the numbers can 14 be correlated.
15 MR. SIESE:
Then tnere is comething wrong with one 16 of thcce studies.
If you can ;et :cre pec;1e killed in the 17 cities than in the whole country, you knew, that is n o *.
18 quite ri7h*.
!f I accept hic ss bein cerrect and your 19 ratics as bein; correct, then : get the urban r.crral 20 trsnsport '. o s a down to around fi.t tire ten to the minus 21 three, the accident ratic.
22 MR. F0?K!SS:
The urban part Of the trans;crt in 23 this study was taken I think to either fite percent er ten 24 percent of the distances thrcu;h urban areas but ' hen the as a.uch hi;her nunter.
Ic I 25 urban population was
.aker ALOERScN REPOR! LNG COMP ANY, 'NC, 400 VIRGINIA AVE.. S W. NASNNGTCN, O C. 20024 ;202) 554 2345
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really don't have a direct way to tell you how much of this 2 would be attributed to the urhan.
3 ME. S!ESS:
You cocid take this one and subtract 4 out your urban and add in the urban from the urban stud y and 5 you come up. with a dif feren t total nutber.
- is still a 6 small number.
Well, it is interestin; but the two aren't 7 compatible.
8 MR. HOPKINS:
Not at t h e
.T,c c e n t.
9 MR. ZUDANS:
Well, th ey shecid be if the correct 10 models aro used.
So that near.s a finer resciution.
11 A?. SIISS:
They were done in the reverse order.
12 That is the trcuble.
13 Y?. ZUDANS:
You see such a tremendous difference 14 where all of the sudden the urban accident case dominates 15 and then you are talking about differences in ycur result of 16 say three Orders of tagnitude and that is a pre tty bi; 17 difference.
18 ME. UCPKINS:
"e a:en't prepared to compare *he 19 two studiss.
i 20 TE. 5:ESS:
It is net incredible because : can 21 si7 ply reduce the normal dcwn to vnere at equals the 1
l i
22 accident lavel, but tha point is that is not right.
The 23 urban redel used in this study and the urban :cdel used in 24 the urban stud y are two different th i n ; s.
25
- ?.
IUDANS:
Which was done first?
ALOE ASON REPcATING OOVP ANY. iNC, 400 VIAGINIA AVE., S W. WASWNGTCN. 3 C 200 4 (202) 554 2345
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MR. SIESS:
This'was done first.-
i sait it vas 2 done in the reverse' order.
j 3'
MR. ZUDANS:. In these accident studies is-the 4
package con sidered designed in acccrdance with the-5 requirements of the reculations?
l 6
- 53. HOPKINS:. For the most pa rt they' vere, but 7 where ve'had specific data on the. response of packages to 8 accident situations we used that specific data.
For.
9 example, we had sampled 63 packages, plutonium packages, and-10 ve knew what their response was for a severe accident.
11.
MR. ZUDbS How sensitive a re the results in the 12 case of an accident, the design quality of the package?
13 Does the iCF per yaar increase linearly?
14 MR. HOPKINS:
It wouldn't incresse linearly 15 because the differences that you would define vould be 16 a ttributable to just one type of package and it veuld only 17 be linear with sepect to the+ kind cf a package?
18 MR. ZUDANS:
Linear?
19 MR. HORKfNS:
It would be linear wherever ycu i
20 applied in a small area and it would he less than linear as r
9 21 applied to the results here.
22 MR. SIISS :
Cov s en s iti v e would the accident 23 results be to different qualification criteria, ray a 24 60-foot drop instead of a 30-foot drop or a iG-foot drop 25 instead of a 27-foot drop?
ALDERSoN REPCRTING COMPANY. !NO.
l 400 VIRGIN A AVE.. S.W.. WASHINGioN. D.C. 20024 (202) 554 2345
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v.B.
F3?<!NS:
All you are doing is reducing the 2
LCF accidents by doing that.
3
- 13. SIE55:
It might not change it at all.
It is 4 not that simple.
! vould have to know whe-your curve was 5 for the assumed accident.
It may be that 30 is cced anouch 6 and 60 is no better.
7 ME. LAN"AAR:
It vould be raducing 4.73 down to 8 u.63 0: so m e thing like th a t.
9 MR. SIISS:
It would make the fire twice as 'ct 10 and the fire can't he twice as hot.
50 it wouldn't N. a k e any 11 difference.
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.c a.~.c. a a 4 s.
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13 believe that they concluded that the 30-foot dro; 4.nd some 14 of these numbers encompasced 99.-something percent of the 15 accide".
s.
16
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T.- " c.>..=.. d.
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18
- 25. SHAPPIET:
Ixcluding air.
They did the same O. c.
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21 be considered.
22 Whose presentation was this?
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MR. HOFKINS:
This was just to in trod uce the 2 regulation 7 which are applied in the risk study.
3 ME. SIESS:
I am going to postpone this but I know 4
ve are going to want to hear from you no matter which way we 5
go.
If I had known we were going to be stact of time we 6 might have rearranged things but we will get back you.
You 7 have been a lot of help being here already.
"tybe we will 8 know better what questions to ask you next time.
9
- would like to gc back to what I started off 10 with.
This is an executive session of the committee and 11 open and we will keep it on the record.
12 When the Transportation Certification Eranch came 13 to us I believe the scope of the review they had in mind was 14 how well their procedures worked to assure compliance with 15 the regulations.
Is that a rearonable statement?
16
- 83. MacDONAlD:
Yes, the certificatice procedures, 17 the re vie w process.
18
". E. SIEES:
The review process and how well they 19 worked.
It involvei the wa y they decide whether the 20 criteria have been met.
I guess it could involve the scopa 21 of their sctivities, the com;etence they have on their staff 22 and how well what they are doing works to ensure compliance 23 with the regulations.
24 That does not address whethsr the reg ula tion: are 25 adequate such that if they sre complied with they would ALCERSoN AEPC ATING COMPANY, iNC.
400 VIRGINIA AVE., S W., W ASHINGToN, D C. 20024 (202) 554 2345
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protect the ha' tith and sa f sty of - the company.
~ hat is i
1 I
2 another-question.
3
'It ddesn 't address th'e question of whether. the NEC i
4. regulations'by themselves are sufficient to protect the 5 health.and safety.
It is pretty obvious that they cannet.be 6 since NEC does not cett into the actual transport and 7
probably cannot gat'into the actual transportation.
8 So the question I think for the subcommittee to 9 discuss is whether we want to accept the initial scope which-r 10 would mean zercing in on th e. certification process and the l
11.
0A proprams review and increction and enforcement which !
12 think ve can't quite leave out.
I guess we could, but that 13 is another extension.
I will put it tha t way.
They certify 1-4 the GA programs.
New, !iE goes in and checks'to see whether 15 people are following those.
16 So what limits should we pisce on our scope?
-One-17 pcssibility is a very narrev linit which is placed On it by 18 the staff which is still ac adequate task to work on.
We i
19 could extend it to the Transpcrtation Certification 3:ench 20 plus the ICE ef fort, which is not much cf an extenzion, er 21 ve can extend it a little further to all of NEC's affort, 22 which again isn't to much of an extension, er we can extend 23 it to looking at the whole system and seeing what we think 24 are the veak spots and what we think 5?C's rc,le is and what 25 NEC 's role should be and hew well it is being carried cut.
ALCER$CN REPORTING COMP ANY,1NC.
400 VIRGINIA AVE., S.W,. W ASHINGTON. D.C. 20024 (202) 554 2345 i
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Carson?
2 MF. MARK 4 I am not sure that ! have a clea r idea, 3
vith the exception of larry, who is going to leave totally 4
before very long.
5 MR. SIESS:
I beg your pardon.
I was followinc 6
protocol and starting with the connittee and I chould have 7 started. with Larry.
8 (lauchter.)
9 X ?.. SHAPPEFT:
Well, i t seems to me'that we are 10 being asked to review the adequacy Of the precedures.
We 11 have a lot of discussion and really background information 12 so far as I can tell en what th e %:C is doin?.
13
- v. a.
.e T. r. e t.-
- va-.-~i..,. -
v- "u *. e..w. e - - o e-d u - a.c, a.
14 into perspective to the relevant problems.
15
- 13. 3H A p PIP,T:
We really haven't gotten to 16 procedures yet that : can ree.
We d0n't really kncw yet 17 what affects their decision: when th e y get applications in 18 and on what basic they ca:< e their decisions.
!t seems to me
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21 adequacy of regulations, I perceive that frc many years of 22 workin; on thoce kinds of thing s, th e d a ta, as* very hi; 23 problen.
There are many teopla whc are werkin on that 24 questien both nati-nally and in terna ti0nall y ?
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ALCEPScN REPORTING COMP ANV, aNC.
400 VI AGINIA AVE.,3 W., W ASHiNGTON. O.C. 20024 (202) 554 2345
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MR. EMAPPEET:
The criteria.
The regulations are 2 now being. brought'into alignment with~the IAEA with much 3 better agreement than there ha s been 'in the';ast.and that
~
4 process will probably continue.
Even when the IAEA 5 regulations get changed in '53 or ' 8 u we will still be 'in 6 much closar compliance that we'are now.
7 I am content personally to not address the 8-question of the afequacy of regulations as nuch as - the r
9 adequacy of precedures as was requested by the staff to 10- start with.
3 11 MR. SIE55:
let e ask you, if we icok at'the 12-adequacy of the procedures in implementing the existin; 13 reculations and the existing criteria, the physical 14 criteria, do you think there is any chance that those 15 criteria vould change significantly our conclusions that the 16 adequacy of tne process should be changed?
17 For example, let's pick one that is not probably 18 at all reasonable, but if we are satisfied that they can 19 evaluate a 30-foot drop 5y analytical means of a spent fuel 20 cask then we would be equally satisfied if that were a t
21 hundred foot drop.
Now, you can extend that to any of the 22 oth er crite ria.
23 YE. ?UDANS:
That is a reasonable state ent.
24 MR. SHAPPE3T:
I wouldn't say all but : would 25 certataly say that most of the physical testing that has ALDERSON REPoRilNG COMPANY, INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 i
245 1
occurred has occurred in the ' framework of either 15 or 3C 1
2 feet.
I personally feel that there are adecuate ways and 3
analytical tools that we feel comfortable with that could 4 handle 30 feet.
5 I think before we would feel adequate at ;oing to, 6 say, 60 or 100 or some different point we would want to make 7 some tests, or at least I would.
8 There is a consideration by the internationel 9 community for at least sore countries te possible extand 10 that, but that may or may not come to pass in the '83 11 regulations, and we can always de that.
That I think tends 12 to stem from the perception not that the regulations don't 13 cover adequa tely the way thinos a re handled now, but ny 14 understandino ic that at least the British are interested in 15 that because cf the possibility of carrying particular 16 naterials on some hi;h-speed trains.
That is not what 1:
17 done now se they are kind of looking ahead.
I think they 18 ar? quite rutisfiad wi th the wa y regulations are so far as 19 normal transp0rtation is concerned.
20 M?. SIESE Did I hear you uce th e ph rase "Wo uld 21 drop nine meters"?
22 ME. Mac00SALD4 Nine meters.
23
- 15. SIISE:
You don't happen to know if it was ten?
24
- ! E. SHAPPERT:
Nine reters ir 3C feet.
25 MR. 5:FFS4
- know, but just picking it Cut of the ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
2a6 1
air you picked 10 meters.
2 MR. GHAPPERT:
Fut it came from the 30 foot.
3 (Laughter.)
4
- 33. SIESE:
They round it off.
5 (Laughter.)
6 MR. SIESS:
'd e r6und it off at 900 degrees C to 7
1475 F.
8 (Laughter.)
9 ME. SHAPPEPT:
It seems to me that one of the 10 things that really we would want to do is porcibly get 11 together and evaluate how we should approach the problem of 12 what questions we would want to ask you.
As menbers of the 13 main committee you might want to ask your concultants 14 questions which in some cases we may be able to answer and 15 some questions not througnout this procedure but we really o
16 haven't ;otten into tha t.
17 It seems to te sisc that if we followed the 18 procedure Of goin; into wnat they asked for we may finf 19 ourselves expanding into armas that see; t0 he particularly 20 appropriate without ne cessa rily startin; Out c;enin; up the 21 can to start with.
I think we will end up 70ing where the 22 lead takes us hut fro: a li mi t e d.
peint of view : don't we 23 necessarily should go that way.
24
- R.
SIESS:
Your rec 02:endation is to start nov 25 and let it take us where it will.
ALDEPSCN AEPC ATING COMP ANY. INC.
400 VIRGINIA AVE,, S/N, W ASHINGTON, O C. 20024 (202) 554 2345
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ME. SIESS:
%e have got to'at this time decide 2 whether.the criteria.are correct.
They have a research-i 3~ project.undarvay.on that.and I think as they cet.results j
f 4
they mi;ht want to discuss those with us.
The first step if' i
5 they don't change-the criteria ~is to'take'the criteris and-
.6 go.on from there.
'7 The question now is how it is goin; to a pply to 8 the other major problem that we limit ourselves.tc the
+
9 present cri teria.
t 10 YE. SHAPPERT:
The ;rocedures, while they.may te 11 adequate n:v, if the regula ticns a re changed, you may not 12 get the same ansvers.
13 ME LA:iCAA2 I am inclined to agree that it would.
14 not be appropriate at the present time te get into the 15 matter of the adequacy of the regulatory' requirements.
That-1 16 would be a very diffiruit and 'very controversisi area.
17 fE. SIISS:
That is a part of what they were 18 quasticning of tyinc it inte the ;3 progrs: and ! think that 19 is why we have got to brin; IEE into it.
Are the precedures P
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=
i 21 centributors to risk, human errorc versus mechanical 22 failures.
Ecth of those are covered by what we de nos in i
1 23 the licensing and in the certification.
l 24
.13. LAiG.AR:
'"he record so far would indicate 25 that the problems with human errorc are mere i.;crtant that i
i ALDERSCN REPcRTiNG COMPANY. INC.
. 4% vlRGINIA AVE., S W., WA3HINGTON. D.C. 20024 (202) 554 2345
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the problems with the desi;n and the fabrication of 2 Containers.
3 ME. SIESS:
Mr. Eisenberg said that on the overall 4 I think it was about 50 percent that was with the human 5 errors, wasn't it?
6 MR. MacDCNALD:
Fifty percent of the norm which 7
was a hundred times maximum.
8 M3. SIESS:
Now, how much of that var in the type 9
"3" packages ! don 't know.
That is a special risk package.
10 I just suspect the normal, it is 90 percent is human error 11 or a hundred percent is human error.
!f the type "3"
12 package is put together right and main tained right it 13 shouldn't cause much problem at all.
14
- I guess you said that with a normal transport with 15 no accident about 50 percent of the dose var frca mistakes 16 thst people make.
That was tne fi;ure, wasn't it?
17
.M E. EISEN?EEG:
No.
The risk from human er:0r for 18 cities was approximately equal to the risk f rc accidents, 19 from vehicular accidente.
20 MR. SIESE:
Eut for the overall study' 21 YR. 20Pi:!N5:
We founc "uman error to be a very 22 small part.
We didn't ever quantify it.
23 MF. "UDANS:
I didn't understand what you said.
24 Would you repeat it?
25 MR. FISENSEi.0:
In the urb?n crudy th. risk from ALCERSCN PEPoATING COMPANY, INC, 400 VIRGINIA AVE., S. N,, WASHINGioN. D C. 20024 (202) 554 2345
.o n o.
1 accidents was s; proximately equal to the risk free human 2
error, meanin; incidents that involved mislabelinc and 3 michandling and not sealing the packages.
4 MR. ZUDANS:
Then you are comparing ac rv.a 1 5
transport with accident?
6 v.. a. r I.e.r v.. c o.; G
-yo.
r 7
MF. SIFSS:
Let take it that you get a nc: mal 8
exposure and normal transport and abnormal conditions, human 9 error and accidents.
'4 h a t is the rela tive divisien among 10 those three.
11 "R.
E!SEN?EEG It ic :cuphly that the accidents 12 fnd the human error were not equal and the normal dose vac 13 somewhat smaller than eit.he r of those.
14 ME. S!ESS:
It would be like 40-u0-20 and 3:-35-30?
15
- v..o..ere.t: :r "av'e 3.: - 3 5.
' 0.
16 MR. L;':G A A F :
The point that ! really had in mind 17 was that the expecures that have resulted 3rca incidents 18 rather than what wa vould call Ordinary normal transporte.
19 The expesures that have resulted f or these incidents have 20 been viewed scre te human er: r than to fault fabrication.
21 MR. S!?SS:
That is what he ac sayin;, that the 22 human in normal transport is much ti;;e: ther the.ornal 23 exposure.
Of course, accidents, we don't know hev n u c t.
Of 24 that is due to human error and how much of that ir due to 25 exceedin; the criteria for the packape and c'. ether it is a l
i i
ALDEPSCN REPORTING COMP ANY,;NC.
400 VIRGINI A AVE., S.'N, W ASHINGTON. O :. 20024 (202) 554 2345
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50-foot drop;instead of a 30-foot drop or-it just wasn't put l
2 together.right or it wasn'.t fabricated right.
3:
MR. BENDER:
I guess I,would have to say-that-if'
.i 4 we are trying to discriminate between 20 percent and 40
.i 5' percent that we'might as well not.
?
6 MR. SIESS:
Yes.
7 MR. BENDER:
If you want to discriminate between 8 20 percent and 2 percent then=I mi7ht call that a 9 significant difference but I don ' t think the other'neans 10 very much.
I 11 MR. SIESS:
- ut the poin t tha t stahted this was 12 saying that what the staff is doing is looking at 13 cer tifica tion of packa gec and they are looking at licensing 14 users and O A programs.and I CE is doinc a ce rtain amount of 15 inspection and enforcement on this.
16 One thin; we could be looking for is should-they.
- 17 be devoting more of their effort to the OA procra: and the 18 procedures and less to the physical certification of 19 packa;es.
20 M2. SHAPPEST:
Well, is certifica tion not part of 21 the procedures?
22 AR. SIESS:
Certification certifies the package, 23 the design of the package.
By procedure I rean the 24 procedure the shipper uses.
25
"?.
IUDi.NS.
That is anc th er a spect.
ALDERSoN REPORTING COMPANY, INC.
400 VIRGINIA AVE., S.W., WASHINGTON, o.C. 20024 (202) 554 2345
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1 YR. SIESS:
" hat he puts int'o that package, how he.
2 checks it o'ut,.does.he put the casket in and does he tighten i
3 the bolts down and does he make a survey after he does it 4 and'does it follow through all of the procedures.
5
.5 ?.. d a c D O!! AL D :
So what is their definition of 6 procedures?
7 MR. SIISS:
'Je. haven' t tried 'to define terms so I i
8 have defined it.
9 (Laughter.)
10 MR. SIISS:
Tha't' is covered under the user license 11 and not under the packace certificaticn.
'4 h a t to dc.is 12 covered under the package certification, het whether or not 13 it is done is covered under the user license.
14
- E.
CHAPPELL:-
What to do is specified in-th e 15 certificate of compliance under Part 71.
16 MR. SIESS:
I have no doubt that what to do is 17 done 99.9 percent of the time, but I an convinced that it-18 isn 't done that often.
Tha t is the distinction Was 19 making.
You cculd have the peffect package and screbodf 20 could still do it wrong.
21 MR. CHA??ILL:
I don't think that hap; ens too 22 often with type "E".
I think that may happen more often 6
23 with type "A".
24
?. R. '-: 0 ? K I.N S :
With the two incidente ve had that 25 is what happened.
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1 ME. SIESS: :On what, type "3"?
e 2
ME. HOPKIN5:-
On. type "3"' packages.
The'
)
3 - radiographer.didn't put the source in-the' middle of the
'l 4 shielding and the Moly-99' radioactive' bulk. shipment.- They 5 were both human error.
E r
k 6
TE. CHAPPIll:
That was before: they had QA, wasn't 7 it?
't 8
ME. HOPKINS:
~Yes.
f 9
MR..SIISS:
I var simply's;eculating en what'we
[
10 might find by reviewing their procedures.
I suspect.that we t
L 11 are not going to find it..
.12
-One thing that bothers ne about this is that the' i
13 experience we got.in what can ;c wrono is not very large.
14 This is usually how we get good systems.
- ie learn froa o
15-mistakes.
'4e can' alwa ys lea rn f rca each mistake somebody 16 makes and if there is;a pattern you can learn a lot mere.
17 At our next meetine we definitely want to hear fro: I F.I and 18 ve are interested in that incident ':e was talking about here..
19 Y3.
'.U D A N S :
Mr. Chairman, en the regulations and 20 rriteria, ! a0 still a little bi t uneasy about the two 21 sources of reculation you have in a type "3"
specification 22 and type "A".
I just want to know what is going to be done i
23 about that?
I 24 MR. SIISS:
I suspect when we write a final report 25 on this the t there vill be scie mentien made Of type
"?"
ALDERSCN REPC ATING COMP ANY,INC, 400 VIRGINIA AVE., S.W., WASHING TCN, D.C. 20024 (202) 554 2345
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specification packages.
I don't like the dual level and I 2
am not convinced they are equal levels.
!f they are equal, 3
they are unnecessary and if they aren't equal, they are 4
wrong.
! think I can find some very simplistic sta teme n ts 5
to make about it, but what is.done about it depends on the 6 r el a tio n shi p of DCT and I know there a re a let of problems 7
because there are hundreds of thousands of 6M's around.
8 The 6M is a specifica tion packa ge.
It meets a 9 very loose DOT specification.
A certificate package has got 10 drawings and very specific things that it rust meet.
All 11 those 6?'s tha t are out in the sorld a re no t slike.
The 12 only thing thsy have in common is that they all meet the DCT 13 specifications.
That is a poli tical problem but it doesn't 14 keep us from writing a note ateut it.
It is not your 15 problem anyway at some levels.
16 Mike.
17
.43. BINDER:
I think cur thcughts have pretty much 18 nailed down the points.
- !a yb e I could restate them in a 19 slightly different form.
"Je clearly do not vant tc try to 20 determine whether the existing cri te ria need to be changed 21 or not.
I think they have been locked at over a number of 22 years by pec;1e who are ex;ert and we probably Cc;ht to stay 23 with what has been established.
24 SE. 3IEEE:
At this time.
25 ME. SENDEE:
Yes, at this tire.
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1 to look.at' those things.
L 2
5R. SIE55:
Nov,Lin~that aspect of it, Mike, IsE 3 is one source of information.
There is not'an.LER system'in l
4 operation on that, is there?
'5-33 5acDONALD No.
[
6 HR. 5IE55 ' The only other source of information e
7 that comes to mind would be to get some of the users in to 8
talk to us.
Is that'What you-are thinking about?
9 MR. BENDER:
' Jell, we may have to have ' users t
10 there.
In.the past we have'fcund out that listening to
~
i 11 people that are subjected to the licensing process is 12 ed uca tional.- Particularly I.think the point that was made l
13 about the fact that truckers and the like, people that are t
14 in the trucking business are not educated to the risk 15 q u e s t i o r.s.
1 16 MR. SIESS:
Now the truckers don't get into this.
17 Tha t is DOT 's job.
i 18 X3.~BENDE3:
I understand that, but I still say 19 that you have ;ot to look at it.
You have pet to think in 20 terms cf how the package l's being handled through the whole I
21 process.
'7e can't afford to ignore it because it is 00T's.
i 7
22 job.
I think'you have got to look at it.
l 23
%E. SIESS -
Then you.are disegreeing with the j
24 consultants and you want to expend the scope of the. review?
25-
- 53. IUDANS:
No, it is not expansicn.
It is ecre l
ALDER $oN REPORTING COMPANY. !NC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
i 256 1
specific.
2 XR. SENDEF:
I am not sure 'the consultants were 3 quite as explicit as that.
4 MR. SlESS:
Then I am confused.
I thought that 5 the verd was getting is that you wanted to review the 6 Transportation Certification Sranch's process to assure 7 compliance wi th the regulations.
Now when we talk about the 8 trucker er the airline or the railroad we are now into a 9 different area, into one of those breader a reas tha t I was 10 Looking at.
That is under DOT's jurisdiction and NRC 11 doesn't have anything to say about it.
12 ME. SENDER:
I don't think, Chet, that we want to 13 try to get over into the OCT's jurisdiction.
We have to 14 look at the end effects and.we have to see whethe r tha t 15 jurisdictional responsibility is compatible with what you 16 are trying to accomplish by the regulations.
17 MR. SIESS:
That is exactly the scope ! suggested 18 as the broader scope.
19 MR. MAEK:
You are sayin; leave the rsgulaticns 20 alone but don't necessarily ste; them, just the 21 certification.
Is that it?
22 dE EINDER:
Yes.
I am raying at least 100k to 23 see what they are and see what is tein; previded to them 24 because the DO~ regulations assume that the shi;;er is not 25 very
?. n e w l a d ; + a b l e and that he in in fact a common carrier ALDERSoN REPCRTING COMP ANY. tNC.
400 VIRGiMA AVE, S.W., 'NASHINGTCN D C. 20024 (202) 554 2345
257 1
with only a nominal kind cf capability.
2 If that is net comtatible with the wa y in which 3
the shipper process has to be handled, then you had better 4 know about it.
5 ME. SIESS:
It spems to me tha t in looking at that 6 that ycu are looking at that in r ela ti o r.
to the criteria, 7 aren't you, or the package certification?
8 ME. EENDEE:
Well, I don't know.
I may be acre 9 familiar with the criteria than I ough t to be te be 10 objective about this thing, but I have been watching that 11 thing develop over 20 years or so and my believe is that the 12 criteria is not the question.
13 ME. SIESS:
Are you thinkin; of the t ra n s po rt a tio n 14 requirements, the DOT requirements, say, in terms of where 15 this stuff in put with other hazardous cargo or hev fast the 16 truck can go or what the qualifications of the driver are?
17 These would all affect the conditions of an accident which 4
18 relate back to the criteria.
19 YE. EINCEE:
~4 e ll, there are certain ass" ;tions 20 that hav e gone into them.
They were developed a let time 21 ago when people were not as envircnmentally conscious of the 22 hazards as they are today sad just being sure that we knov 23 the assumptions would be 24 M?. SIESS:
In relation to th e criteria ?
25 dE. EESOIE:
In relation to the criterit.
I am ALDEASoN REPORTING COMPANY, JNC,
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400 VI AGINI A AVE., 5 W.. W ASHINGToN. O.C. 200:4 (202) 554 2345 l
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not pulling to chance it, but I think we ought to know wha t 2
they are.
3 MR. SIESS:
k'ha t is your contractor doing in his 4 motor study?
!s he looking at that cort cf thing?
5 MR. CHA?? ELL:
The r.otor study has just started 6 and,i t is constructed in several phases and only the first 7 phase has been initiated.
Richt now they are looking at two 8 modes of transport, truck and rail, and they are evaluating 9 the severity of tne trans;ortatio.i accident a nd icoking at 10 the physical test of packages that would replicate thece 11 con di tio n s.
12 Eventually they intend to test iifferent types of 13 packages to those conditions to evaluata if the type of 14 acceotanca standards are reasonable and practical to meet.
15 They are going to do risk studies to correlate those 16 acceptance sta nda rd s.
17 The net effect of the studies would perhaps be 18 that we have tests that are more stringent and ace' tance 19 standards that are more realistic.
20
!?. 5 ESE.
" hat fit;e is s ug; e s t i r.g is that are 21 they looking at those severity of accidents as a ' unction of 4
22 the DC~ regulations on transportation?
i I
1 23 XE. CHA?? ELL:
They are look.ing at accidents at i
4 i
24 the upper amount of severity.
The type of correlation :
25 think you are speaking of, that is it relates the velirity i
ALOERSoN REPORTING OoMPANY,;NC, 400 VIRGINIA AVE., S W., N ASHINGToN D C. 20024 (202) 554-2345
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-259 l
1 of ispact to probability of occurrence, was done by Sandia.
l 2 - several years'ago.
There are nice curves ' tha t rela te fire 3 duration and impact velocity and the probability of those..
4 MR. SIESS:
Mike apparently knows more about the 5
DOT regulations than I do.
Are there DOT.regulaticns that 6 are intended to reduce the severity.of an accident?
i 7
3R. BENDER:
I'would say the answer is'no.
~
8 MR. CHAPPEll:
There is more than one k'ind of 9 standard here.
Ihere is a standard tha t ycu test the' t.
10 ' package to for an eccident survivability and that is the 11 kind of report seen on the motor study.
Th en thara.are ' the 12 type of standards of how large can the dose be fr:0 a single i
13 package or from a vehicle or how large can the dose be
- i n
i 14 - fcllowing an accident.
15 MR. SIE55:
Well, I don't understand vike's 1
16 concern with the DOT 's standard s then.
?o you understand i
17 wha t <his concern is?
i 4
l 18 MR. MacDONA1Da
'4 ell, I think it is the question 19 of usually you say well can this event happen in i
20 transportation where jou. ave a prepane tank blev-up or 21. something.
Well, let's put rcre additional strencth and i
22 intecrity inte radicactive material packages rather than j
23 lookinc at that propane tank and seeing ho"
- ~'
make it 2
i
(
24 -more accident resistant er fire resistant.
upgrade 25 the packaging f or other harardcus taterials.
y00 1
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don't have to put se much inte the radioactive m'aterials.
2 dE. SINOEE:
I am not thinkinh about that.
As a 3 matter of fact, I am not suggesting that we try to change 4
the standards on the ba sis of what constraints migh t be in 5
DOT, but I do think that we ought to think about it.
IfDCT 6 do"esn't require that the truck driver know something about 7 radiation safety, can you impose that r eq uire m e n t on him?
8 That is the kind of question ! think we have to ask 9 ourselves.
If you can't, then there is no sense in saying I 10 as going to have some kind of requirement for radiation 11 safety educati-" in the trucking industry because you are 12 going to c h, *, g e ti regulations.
13 ME. ??v25:
You are talking about scue Of the 14 stuff Stan var talkinc about like the emergency preparedners.
15 ME. 3ENDIE:
Sure.
I thin k that is more the line 16 of logic that Ia going to and not the accident itself.
17 ME. MacDONALD:
Okay.
Well, DCT ir a ddre ssing 18 that in this : Ore recent routing rule.
One of the facets of 19 the routing rule was t ra ini ng and driver re;uirerents.
T ". e y 20 are getting into that area.
t 21 ME. 3ESCEE:
As a matter Of fact, I think even the 22 trucking industry is goin; through its Own agonies of change 23 becausa, it is like wh a t Chet cays, we hear about one of 24 these damn things every week and they are te7inninq feel 25 the 1 ;act.
ALOERSCN REPCATING COMP ANY, :NC, 400 VIRGINIA AVE., S/N, WASHINoTCN. O C. 20C24 (202) 554 2045
261 l
l 1
- E.
SIESS:
All they do is kill drivers.
2 (Laughter.)
3 ME. EENDEE:
So far.
4 ME. SIESS:
" ell, I think I understand and ! think 5
we can start off in the direction that has been indicated.
6 The consensus seems to be, getting now to you, 7 Carson, that we should limit ourselves initally to the scope 8
that the staff requested.
9
- 53. MARK:
I sensed that.
10 ME. SISSS:
And that we not at this time review 11 the criteria, although we ticht suggest to the staff that 12 when th ey get the results of that T.cdal study that we would 13 be happy to look into the criteria and that we do consider 14 in our other part of the review the possibility that 15 criteria may change and may have some impact on their 16 process or their procedures.
If that limited study tends to 17 tak e us in other directions as questions cone up keeping 18 t h e r, focused there that va vill gc off in those directions.
19 Now, I have some specifics I wanted to bring up.
20 I have gotten some answers here to many things.
I think 21 with that limited scope we are going to want, and by "we" I
22 mean com.mittee members and all of the consultants, to look 23 at some SA?/SE?s.
24 v?. M.;3K:
Not many.
25 (lauchter )
I ALOERSoN AEPo ATING CCVPANY. INC.
400 VIRGINIA AVE., S.W., 'NASH!NGTCN, D.C. 20024 i202) 554 2345
262 1
MR. SIESSi Well,'not many big ones, but we might-2 vant to arrance to get some of the large ones or one or two
+
3 in the hand s-cf our consultants to review.
Would that.be i
4 poossible?
We vill work out who gets what and we vill ask 5 for volunteers.
6 I.had a note.here whether at future meetings.ve' 1
7' would want to talk to any of the DCT.
We had a'DGE 8 representative this morning.
Iut if we vant'to talk to DOT, 9 I would say possibly yes but 'somewhere f arther down the line 10 in view of the scope we have set until we get clea r of where i
11 ve want to go en what Mike has preposed.
12 Do we want to talk to any state representatives 13 that do some of the same things you de to get sore. feel for 14 that?
I would say tentatively no if we limit curselves as-15 ve have said to what you are doing.
16 You have get contractors on the rodal study which i
17 ve vill defer.
livermore does some verk fer you and at some 18 point we might want to talk to them, but vculd enly be if 19 you think that that vculd be helpful.
I e
20 We might want to' talk to some peo;1e f r c...
6 i
21 industry, that is package desi;ners and manufacturers if 22 'they are in the business, to.see_vhat they de, but I think 23 Mr. langaar has had guite a bit of experience in that area r
24 in designing packages I believe, right?
4 25 ME. LA50AAE:
Yes.
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400 VIRGINIA AVE S.W., WASHINGTON. 3 C. 20C24 (202) 5$4 2345
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- 33. SISSS:
We ray nct have to ;c cut fer that.
2 Users, they might he verthwhile, but it ust be a 3
tremendous range of users, everywhere from the utilities 4 devn to -- vell, I don 't know how far devn it sces to hov 5 little.
6 Padicgra phers.
They are a bout as far down as you 7 get.
8 (Lauchter.)
9 MF. SISSS:
" ell, I mean shi;;ing users and not 10 the guy tha t is using the pr0 duct.
I gave u; on the 11 radiographers g0ing around the truck and 10 sing the source.
12 ME. Mac?ONALDs We are still verking with the.
13 X?. SIESS:
Eut that is not within your sco;e 14 really.
15 YE. MacCONALO:
" ell, s'ose of the packa es that 16 they use are type "E".
17 ZE. SIESS:
If you could give us sort of a 18 repre sen tative list of *y;es cf users ther naybe we could 19 vork out with you two cr three that we would vant to talk 0
20 at some ;oint.
That would be :cre ir the license end and 21 not the certification end.
We vill see wh e the r we eed to 22 ;et into the user ty;e er the anufacturer type, the ;orsen 23
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.u 25 was a questien raised about a differing pr0fessi0nal ALOERSCN :E AC AT!NG COVD ANV, '.NO, 400 VIRGIN!A A/E.. S.W. W ASHING TCN D 0 20G24 (202) $$4 2345
264 1
1 opinion.
Did you ever find out what that was?
2
- f p, gaccoyA1
- 4 i! o,
3 3R. SIESS:
I saw your letter.
4 MR. MacDONALD:
There was a letter and te my 5 knowledge there has been no response to that letter.
6 MR. SIESS:
Okay.
If something does come in we 7 will expect to hear from you.
8 Now, at the next meeting ve have we would 9 definitely want to hear from ICE and it seems to me we will 10 vant to hear a lot more from you fellows to begin with en 11 the mechanics of the package certifica tion and maybe + eking 12 a more detailed look at the procedures in the sense ! was 13 using it before, the procedural requirements en the user and 14 what he does about them, his CA program if you wish which 4
15 sort of ties him with the ICI staff.
i 16 Then I think before the next meeting we would want 17 to get some of our consultants to look at a selective 18 SAE/SEE type thing.
! am sure yo u would li k e to look at 19 that or are ycu familiar with those enough that you don't 20 want to see them?
21 ME. lANGAAR:
Well, : am ra the r f amilia r with 22 them, but I would be happy to review one.
l 23 X3. SIISS:
Would you fellows suggest to us maybe 24 a small set of SAE/ SEES that could be transmitted to the 25 consultants for review?
ALDERScN REPCRTING OCMPANY. INC.
400 VIRGiNI A AVE., S.'N.. WASHINGTON. D C. 20024 (202) 554 2345 l
t
.265 1
Do you..vant the ones-that are t
2 currently under review or something~ that has already-been 3 -done?
t 4
ME. SIESS:
No, something that ha s already been t
5 ' don e, but, you know, recent enough that it is typical-of 6'
what you are doing and it.woul'd be representative.
I cuess k
7 we.would like to have, say, one.cn.a cask and then something 7
8 further down the line.
I don.'t know how many categories ycu 9 put.these in..You.had 'a collecticn of ' slides 'there 10 barlier.- We would let you select what you think is a 11 representative group.
12
- 03. ZUDASS:
Mr. Chairman, I would like to see i
13 that move sometime but not necessarily today.
14 MR. SIESS:
Well, we could do it today unless 16 these guys have got to catch a bus.
16 ME. CHAPPE1L:
Well, it is a good mcVie.
17 (laughter.)
18.
"E.
2AEK:
I had a question I vculd like to have 19 answer'ed n0w if it can be easily.
You had that number of 20 one LCF for normal behavier in 1975.
Now, th a t of course is 21 not a number that anybody kncvs he just invents.
What you 22 have'probably come closer te determining is
'".at there is 23 ten to the fourth man-rem per year.
24 MR. HOPKINS:
Yec, 9,000-snd-some man rem.
25 ME. "AEk.
And then you :ude the assur tion that
+
ALDERSON REPCRTING COMPANY, INC.
i i
400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554 2345
266 1
it is higher for a million.
2
- v. c..
u.. n M. 2".. e -
yee.
w.
3 vE. MARK.
Of tha t ten to the f ourth what fraction 4 adhered to the people you can call transportation workers 5 lik e the handlers in the cheds or the drivers in th e va ns?
6 Were they almcst all those people?
7 ME. HCPKINS:
It is all spelled out in Chapter 4 8
M.E. SIESS:
Airline stewardesses, cargo handlers i
9 and van drivers.
1 10 ME. MAEK:
?.cstly those.
11 MR. SIESS:
Have you read it?
12 d5. MAEK:
I haven't locked at it.
13 ME. SIESS:
You shculd read it.
It is a 14 f ascina ting dccument.
15 ME. MARK:
I have read so.'e of it.
i 16 MF. 4CPKINS:
Of the 9,800 p e r sen -r e r total 3,000 17 rent te crew of all kinds and mostly truck, 2,C00 vant to 18 passengers and passenger-carryin; aircraft a r. d
,CCO tc 19 bystanders at stops and 1,700 to handlers.
20 v?. MA?K.
So it is really caly
,000 t: the 21 public at large except for the passengers.
22 MR. ECPKINS:
Yes.
23 M?. 5:535:
Airrrait passengers were h e *. many 24 thousand?
25 ME. -0? TINS:
7.enty-three hundred.
ALOEPSCN AEPoRT;NG c0MP ANY. :Nc.
400 VIRGIN! A AVE., SJN. W ASHINGioN. D C. 200241202) 554 2345
.. = - -
1 267 i
-1 MP. SIESS4 Of which smokerr get three-fourths.
2 (laughter.)
3 MR.
ARK:
You sentioned two or tnree other. people
'?
4 who were interested in making packages which you want 5 certified.
Perhaps you could get a. core f ully 6 representative list.- Who is interested ~1n making the l
7 packages which you' feel you.must certify..You-mentioned.
8 National lead and you have mentioned GE.
9 M3. MacDONA1Ds It would be people like Sterling 10 Rogers.
11 MR. EIESS:
Is there.an index in the back cf that i
t 12 thing that you sent ns?
13 MS. MacDONA10:
Of the NUEEG document, Of'the 383?
.:r 14 ME. SIESS:- The three orange volumes.
i 15
- 33. gaccosA;;
yes.
It'wculd not have the 16 manufacturers in there.
It would have all of the users.
17 v..
r,. a K s Well, the manufacturere, a;;arently you e
18 are vendering if they all knew what a CA p r e g r a.? really is.
1 i
19 GE does and National Lead.prc'cahiy des.
The Other name you 1
t 20 mentioned, I don't know if they wculd or net.
21 MR.*MacDCNAlts Yes, they know.
l 22 ME. IIESE:
'4 ave yce ;ot a list of manufseturars?
l 23 53.-Tac 00NA13:
Nc.
We would have to ;et that 4
24 together as to the persons who manufacturered cur existinc 25 packagos.
The TFA-c that was shown this morning, rene are l
ALDERSON AEPoRTING COMPANY. iNC.
]
400 VIRGINI A AVE., S.W., 'NASHINGTON. O C. 20024 (202) 554 2345 i
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-1 manuf actured. it in _ Erance by Rogatelle.
venithouch.they' I
r 2' are overseas they are still inspected by the IEE.
They.do-3' have an oversees inspection pr'ogram'also.
So.it is not only-i t
.4 limited to~the United-States.
5 M.E. MAEK:
I-think if it sounds all right', Chet, e
6 -just to comment on something to.give the spread-of this-and I
7 the measure ar to whether they are very large or very s !t a ll --
8 companies.
9-
- 33. SIISS:
Is that something that !EE should do 10 and not you?
11 MR. MacDONALD:
Nell, we can work together.
i, 12 YE. MARK:
It vould only need to be a.two-minute i
13 account.
14 13 -. NacDONALO:
Yes.
It depends if we are i
15 talking, you knew, about the large-fusi cask wh1:5 is rather' 16 limited in six or seven designs. 'That will be eacy enough 17 to see who fabricated those packages.
f 18 MR. SIESS:
'> c w m a n ;. truck packa;es are there?
19 ME.'Mac0CNAL;s Well, I think
- .e ended u; with the.
e 20 four lef t over.
f i
i 21 (Laughter.)
.~
22
- 93. "AEX:
You m+an that hadn't been tested to 23 death?
1 24 (laughter.)
25
%. Mac0CNALO:
Wha te ver we had left ever f ro.?
the P
h i
4 l
ALOERSoN AEPoRTiNG COMPANY. ;NC.
400 VI AGINIA AVE., S.W., WASHINGioN. O C. 20024 (202) 554 2345 i
_ -, - _ _ _. _ -, -...., -. _. - -,... _,. - - -., _ _, _ _ _ - _... ~ _,. _., _ _
o r. o.
1 program we gave away to the IAIA and to the repartment of 2
nergy.
3
%3. SIESS:
%e paid for these.
You should have 4 sold them.
5 (lauchter.)
6 MP..MacDON.11D:
There is a petty pass under 7 development which will be for a pe ttigra m sample.
We expect 8 to get that application in the next contP cr so.
Maybe that 9 is one that the consultants would like to look at in the 10 active review program.
11 YE. SIESS:
"as it been analyzed?
12 M?. MacCCNAlD:
!t will ha ve been cc pletely 13 tested and the safety analysis repc:t written.
14 MR. SIESS:
I just wendered if they were going to 15 analyze it instead cf testing it.
16 Well, I will get toge the r with Sa. and we will 17 cook up a next meeting.
I don't think it is going to be the 18 week of the full ec::ittee meeting and I want a better r os.
19 Co you want to take a coupls of minutes for t ". e 20 movie?
Tha t vill give us a little break.
21 (Twc short films were shown.)
22 (Whereupon, at 4:40 p.m.,
the subcortittee 4
23 adourned.)
l 24 25 i
ALCERSON REPCRTlNG OOMPANY. ;NC.
400 VIRGINIA AVE., S.W., WASH NGTCN. 3 C. 20024 (202) 5$4 2345 l
l e
NUCrIAR RIGULATORY CO.SC4ISSICN This is Oc certify tha: the attached proceedings before :he
. )
v.
13 Uh 3100 er C f *- ACRS/ Subcommittee on Transportation of Radioactive Mateirais-
' Date of ?roceeding:
.tarch 10, 1981 Decket !!u=b er:
Place of ?receeding:
Washincton, D.
C.
were held 'as herein appears, and tha: this.i: the original transcrip i therecf for the fila of the Cctsissi:n.
Anne Morewith.
OfficiaJ :.~eper:er (Typed)
[
Official Reporter (Signature) 4 N
fa-Q aJ.
e NUC*2AR REGULATOP3 COMMISSICli This is Oc certif/- tha: the a:: ached proceedings before :he
- )T l
in the ma.tter of:. ACRS/ Subcommittee on Transportation of Radioactive Materials Date-cf ?rcceeding:
March 10, 1981 Decket !!u=b er:
ashington, D.
C.
W
.s i c e c.. = ~. c =. a.d.e.,. -.
-a were held as herein appears, and tha: this is the criginal :ranscrip:
therec f for the file-of :he.Cecmission.,
Patricia A. Minson Of fic.127 Repcriar (I'/;ed.}
t/[ & 4 s. W --
Cf ficial Repcrter (5igna ure) d J
f'.)
)
NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings.before the iI in the matter of: ACRS/ Subcommittee on Transportation of Radioactive Materials
- Date of Proceeding:
March 10, 1981 Docket tiumber:
? lace of Proceeding:
Washington, D.
C.
were held as herein appears, and that this is the original transcript thereof for the file of the Consission.,
Mary C.
Simons Official Reporter (T/ ped)
/
5 g
M M}>_=
Official Reporter (Signature) t J
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s Form f4RC414 U.s. NUCLEAR REGULATORY Commission U2 3)
,g g g g CERTIFICATE OF C051PLIANCE For Radioactive Materials Packages 1.!al certifiante Nummer 1.(b) Rowision No.
1.tc) Package identincation No.
1.[d) Pages No. 1.(e) Total No. Pages 4010 7
IK A /4010/ A / TF 1
9
- 2. PReAMeLE 2.la)
This certifieste is issued to satisfy sections 173.393a.173.394,173.39s. and 173.396 of the Department of Transportat Materials Regulations (49 CFM 170-189 and 14 CPR 103) and Sections 146-19-toa and Transportation Dangerous Cargoes Regulations (46 cFR 146-1491. as amended.
146-19-100 of the escartrnent of 2.th)
The onckaging and contents described in item s below meets t.*.e safety standards set forth in suenart C of Title to. code Federal Regulations. Part 71," Packaging of Radioactive Materia 6s for Transport and Transportation of Radioactive M Cartain Conditions-2.(c)
This certificate does not relieve the consignor from compliance with any roouirernent of the regulations of the U.s. Dep Transoortation or other asoilcable regulatory agencies. including the gowrntnent of any country through or into w will be trensoorted.
- 3. This certincete is issued on the bases of a safety analysis resort of the package design or'applicatiork 3.(a)
Preserod Dy (Name and address):
3.tbl Titte and identification of report or soolication:
NL Industries, Inc.
NL Industries, Inc. application dated Nuclear Division March 7, 1980, as supplemented.
P.O. Box 2046 Wilmington, DE 19899 3.fc) oce=et No.
71-9010 4 CoNelTioNs This certificate is conditional upon the fulfilling of the requirunetts of suboort o of to CFR 71. as soolicable, and the condit l
in item s below.
- s. oescription of Packaging and Autnorized Contents. Mooal Nurnoer, Fissile Class, other Conditions, and
References:
(a) Packaging (1) Model No.: NLI-1/2 (2) Description j
A depleted uranium, water, and lead shielded shipping cask, encased in stainless
- steel, and equipped with balsa impact limiters. The cylindrical cask body is 195-1/4 inches long by 47-1/8 inches 00. The principal shielding consists of l
2-3/4 inches of depleted uranium, 2-1/8 inches of lead, and 5 inches of water.
6 A 7/8-inch thick stainless steel outer shell is welded to a solid stainless steel forging at each end of the cask. The outer shell of the cask is sur-rounded by a 1/4-inch thick steel water. jacket that is also attached to the end forgings. A water expansion tank is welded to the water jacket shell. The innter cask cavity is formed by a 1/2-inch thick, stainless steel cylindrical shell; welded.at its top end to the upper cask forging and at its bottom end to a circular plate.
There are two separate configurations of the cask.
t 6
Configuration (A): The containment vessel is a right circular stainless steel
{
shell, 12-5/8 inches ID by 178 inches inside length by 1/4-inch thick, located within the inner cask cavity. The containment vessel is closed and sealed by a 5-inch thick, composite steel and uranium closure head, twelve, 1-inch diameter bolts, and a silver plated, metallic 0-rir.g.
Eight of the twelve closure bolts 357 e
y m
--v,--
Page 2 - Certificate No. 9010 - Revision No. 7 - Docket No. 71-9010 5.
(a) Packaging (continued)
(2) Description (continued) are used to secure the containment vessel to the upper cask forging.
Closure of the cask cavity is by a 1-1/2-inch thick steel closure head, eight,1-inch diameter bolts, and elastomer 0-ring. The radioactive contents are positioned and supported within the containment vessel (inner container) by an aluminum basket and internal support structure.
r Configuration (B): The containment vessel is the 1/2-inch thick inner cavity shell. The 1/4-inch thick inner container is not used. The cask cavity is closed by two closure heads. The inner head is a 6-inch thick, composite steel and uranium plate secured to the upper cask forging by-twelve,1-inch diameter bolts and sealed with a silver plated, metallic 0-ring. The outer head is 1-1/2-inch thick steel plate secured to the top of the upper cask forging by eight,1-inch diameter bolts and sealoj with an elastomer 0 ring. The radioactive contents are positioned and supported within the containment vessel (inner cask cavity) by a modified aluminum basket and internal support structure.
The package, including impact limiters, has an overall length of 237 inches and an outside diameter of 75 inches. The maximum weight of the contents is 1,600 pounds. The weight of the package is approximately 47,500 pounds.
(3) Orawings The Model No. NLI-1/2 shipping cask is constructed in accordance with the following National Lead Company Drawing Nos.:
General 70514F, Sheet 1, Rev. 7, Cask and Trailer General Arrangement 70514F, Sheet 2, Rev. 8, Cask and Trailer General Arrangement 70885F, Sheet 1, Rev. 3, Spent Fuel Cask Details 70885F, Sheet 2, Rev. 2, Spent Fuel Cask Details 70885F, Sheet 3, Rev. 2, Spent Fuel Cask Details 70885F, Sheet 4, Rev. 1, Spent Fuel Cask Details 70887F, Sheet 1, Rev. 1, Outer Closure Head Confiouration (A) 70516F, Sheet 1, Rev. 8, Spent Fuel Cask General Assembly 70562F, Sheet 1, Rev. 8, Inner Container 70562F, Sheet 2, Rev. 4, Inner Container Configuration (B) 70888F, Sheet 1, Rev. 3, Spent Fuel Cask General Assembly 70886F, Sheet 1, Rev. 2, Basket Concept 70884F, Sheet 1, Rev. 2, Inner Closure Head
?
358
h Page 3 - Certificate No. 9010 - Revision No. 7 - Docket No. 71-9010 h
n V
V b
(b) Contents
,i:
(1) Type and form of material l-(i) Irradiated PWR or BWR uranium oxide fuel assemblies of the following
@d specifications:
pWR BWR t
b Fuel form Clao U02 pellets Clad UO2 pallets Cladding material Ir or SS Zr or SS j
- )
Maximum initial fuel pin pressure at 100*F, y
psig 550 200 l' i.
Maximum initial U content / assembly, kg 475 197 k
Maximum average initial U-235 enrichment, w/o-3.70 2.65 j;
I' Maximum bundle cross section, inches 8.75 5.75 L
Fuel pin array size 14x14/15x15 7x7 t
16x16/17x17 8x8 Maximum active fuel length, inches 144 144 Maximum specific power,
- D kw/kgU 40 27 Maximum average burnup, 40,000 34,000 MWD /MTU Minimum cooling time, days 150*
120 5
i.
The PwR type assemolies may be shipped either with or without I
burnable paison rods or control rods.
- Four (4) fuel rods may have minimum cooling time of 120 days.
t 25+
+
e
Page 4 - Certificate No. 9010 - Revision No. 7 - Docket No. 71-9010 5.
(b) Contents (continued)
(1) Type and form of material (continued)
"(ii) Solid, non-fissile,. irradiated hardware and neutron source components.
(iii) Byproduct and special nuclear material in the form of irradiated uranium and plutonium oxide fuel rods.
Prior to irradiation, the maxi-mum enrichment in U-235 plus plutonium not to exceed 3.70 w/o.
(iv) Irradiated PWR uranium oxide fuel assemblies including additional irradiated fuel rods inserted and secured in the guide thimbles.
The fuel assemblies shall conform to the maximum active dimensions as described in Item 5(b)(1)(i) except that maximum initial U content shall be 495 kg and the maximum average initial U-235 enrichment shall be 3.35 w/o.
,t (2) Maximum Quantity of. material per op;kage The maximum decay heat load per package not to exceed 10.6 kilowatts.
and; (i) Items 5(b)(1)(i) or 5(b)(1)(iv) above: one (1) PWR fuel assemoly; or two (2) BWR fuel assemblies.
Above assemblies to be contained in their respective fuel baskets as shown on National Lead Company Drawing No. 70562F, Sheet 1, Rev. 8 or 70886F, Sheet 1, Rev. 2.
(ii) Item 5(b)(1)(ii) above, weight not to exceed 1,600 pounds.
(iii) It'em 5(b)(1)(iii) above, the maximum mass of U-235 plus plutonium shall not exceed 4.0 kg.
Fuel rods shall be contained in fuel baskets as shown on National Lead Company Drawing No. 70562F.
Sheet 1, Rev. 8 or 70886F, Sheet 1, Rev. 2.
(c) Fissile Class III Maximum number of packages per shipment One (1) 6.
The cask cavity and containment vessel (inner container) shall be dry (no free water) when delivered to a carrier for transport. Residual moisture shall be removed from the cask cavity and containment vessel by the methods described in Section XV of the Application. Removal of residual moisture from cask cavity 1
when package is used in Configuration (B) is not required providing the decay heat load does not exceed 2 KW.
The containment vessel shall be filled with 1 ATM of helium.
7.
Prior to each shipment, the package shall meet the tests and criteria specified
- in Section XVI of the Application.
1
?
~
360
~
-... -.. ~
T
i-Page 5 - Certificate No. 9010 - Revision No. 7 - 00cket No. 71-9010 J
8.
The helium coolant is considered part of the package contents. The radioactive a
limits specified in 10 CFR $71.35(a)(4) do not apply.
S 9.
The package contents shall be so limited that under normal conditions of transport, the sum of the gamma and neutron dose rates shall not exceed 21 mrem /hr when measured M
at a distance of three (3) feet from the exterior surface of the package.
S7
- 10. The neutron shielding tank shall be fill'ed with a mixture of water and ethylene glycol (52% by volume).
J
- 11. The structures used to support the package on the transport vehicle shall be as described in the Application.
RP 12.
Any system used for cooling down the package shall be provided with a pressure relief if device set so that during the cool-down process, the maximum pressure in the contain-h ment vessel cannot exceed 310 psig when the package is used in Configuration (A) or IT 365 psig when the package is used in Configuration (B).
y 13.
The systems and components of each packaging shall meet the periodic tests and
- riteria specified in Section XVI of the Application.
L 14.
Repair and maintenance shall be as described in Section XVI of the Application.
l 15.
As needed, appropriate component spacers shall be used in the cask cavity to licit movement of contents during shipment.
l.
16.
Prior to first use, each packaging shall meet the acceptance tests and criteria specified in Sections XIII and XIV of the Application when used in Configuration (A)
]
and in Appendix A to Sections XIII and XIV when used in Configuration (8).
[
t 17.
The package authorized by this certificate is hereby approved for use under the ll general license provisions of 10 CFR 571.12(b).
18.
Expiration date: March 31, 1985.
L REFERENCES l'
NL Industries, Inc. application dated March 7, 1980.
Supplement dated: July 11, 1980.
Ir FOR Thi U.5. NUCLEAR REGULATORY COMMISSION h
hlh 1
Charles E. MacDonald, Chief Transportati'on Certification Branch Division of Fuel Cycle and Material Safety JUL 1 g 1380 Date:
3o1
f i
i i
i i
^
U.S. NUCLEAR REOULATORY COMMISSION i
SUMMARY
REPORT OF N.R.C. APPROVED PACKAGES PAGE IB6
{
NOVEMBER 30, 1980 a'
NNNNNNNNNNNNNNNNNMMNNNNNNN
{
NM M M M N N M M N N M M M M N N N N N M M M N N N N N N N N N A V41N N N N NNN NN NN N NN N NM KEY I.D. CODES 9010 NNNNNM NNNNNNNNNNNNNNNNNNNNNMMNNM
]
NN CERTIFICATE DATA NM CERTIFICATE Ne.s 9019 REVISION No.s 7
DOCKET NO.s 71-9010 EXPIRATION DATES 03/3t/8S MODEL NO.s NLI-1/2 PACKAGE I.D. NO.s USA /9010/8( 3F PACKAGING TYPES IRRADIATED FUEL MM PKG. DESCRIPTION MN IRRAD FUEL SHIPPING ANGLE, MAX U-23S ENRICH 3.35 W/0, FISS CL III. DPTD U H20 PB SHIELDING ENCASED IN S.S. CYL. BODY. 2.75" DPTD. Us 2.l3"PB & S i
l
- H20. 237" LNG INCL. BALSA IMPACT LIMITERS X 75" 00. CLOSURE OF CONT. VE SSEL SY 12 BOLTS la DIA. DRY ME FILLED TRANSPORT & OTHER SPEC LIMITS. MAX j
CONT NT. 1600 LBS. GROSS WT 47,500 LBS.
i j
GENERAL LICENSE ISSUEDs YES i
l NN USERS MN BALTIMORE GAS & ELECTRIC CO.
P. O. BOX 1975 BALTIM0RE MD 21203 ATTH: HR. A. E. L26DVALL, JR.
MRC LICENSEE SECONDARY BATTELLE COLLMAUS LABORA1 CRY SOS KING AVENUE COLUMBUS ON 43208 ATTH: Mk. HARLEY L. T0Y NRC LICENSEE SECONDARY I
BOSTON EDISON COMPANY 800 BOYLSTON STREET BOSTON MA 92199 ATIN MR. G. CARL AND00NINI NUCLEAR OPERATIONS DEPT. NRC LICENSEE SECONDARY CAROLINA POWER & LIGHT Co.
ROUIE le BOX 327 NEW NILL.
NC 27562 ATTN MR. B.N. WEBSTER HRC LICENSEE SECONDARY CHEM-HUCLEAR SYSTEMS, INC.
P.O. BOX 1866 RELLEVUE WA 98009 ATTMs MR. LOUIS E. REYNOLDS NRC LICENSEE SECONDARY 4
COMMONWEALTH EDISON 22710 206 AVENUE NORTH CORDOVA IL 61242 ATTN 8 H.J.KALIVIANAKIS QUAD-CITIES STH.
MRC LICENSEE SECONDARY DEPARTMENT OF ENERGY P.O. BOX 14100 LAS VEGAS NV 89114 ATINs MR. A. T. NEWMANN HEVADA OPERATIONS OFFICE DOE SECONDARY E G & G ENERGY MEASUREMENTS P.O. BOX 19t2 LAS VEGAS MV 89108 ATTN 8 MR. PATRICK C. MURPHY JR DOE SECONDARY FLORIDA POWER & LIGHT Co.
P.O. BOX 529100 MIAMI FL 33152 ATTNs MR. ROBERT E. UNRIO NRC LICENSEE SECONDARY
t PAGE 147 U.S. HUCLEAR RE00LATGRY COMMI55IDH l
5UMMARY REPORT OF H.R.C. APPROVED PACKAGES I
NOVEMBER 30, 1980 NNNNNNNNNNNNNNNNNNNMMNNNMMNNNNNNNNNNNNNNNNNNNMMNNNNNNNNNNNNNNNNNNNNNNNNNN NNNNNNNNNNNNNNNNNNNNNMMNNNNMMNNNhnNNNNNNNNNNNNNNNNNNN KEY I.D. CODES 9080 I
NNMMMMNNNNNNNNNNNNNNNNNNNN NW CERTIFICATE DATA NM CERTIFICATE HD.
9010 REVISIGH HD.:
7 DOCKET N0.8 71-9018 EXPIRATIDH DATE: 03/31/85 i
MODEL HD.8 HLI-1/2 PACKAGE I.D. H0.8 USA /9010/B( )F PACKAGING TYPEe IRRADIATED FUEL j
NN PXO. DESCRIPTIDH NN IRRAD FUEL 5 HIPPING AHOLE, MAX U-235 EHRICH 3.35 W/0, FISS CL III. DFTD U
, H20, PB SHIELDING ENCASED IN 5.5. CYL. BODY. 2.75" DPTD. Us 2.13"PB 8 5
" H20. 237" LHO INCL. BALSA IMPACT LIMITER 5 X 75" OD. CLOSURE OF CONT. VE T
55EL BY 12 BOLT 5 la DIA. DRY HE FILLED TRANSPORT & OTHER SPEC LIMIT 5. MAX CONT WT. 1688 LB5. OR055 WT 47,500 LBS.
GENERAL LICENSE ISSUEDs YE5 MN USERS MN OEHERAL ELECTRIC CD.
175 CURTHER AVE.
SAN JOSE CA 95125 HRC LICENSEE SECONDARY ATTH: MR. D. M. DAW 50H HITTMAN HUCLEAR & DEV. CORP.
1190 RED BRAtiCH RD.
COLUMBIA MD 21045 l
AGREEMENT STATE SECONDARY ATTMs MR. DALE SILLYMAN HORTHERH STATES POWER CO.
414 NICOLLET MALL STH FLR.
MIMMEAPOLIS MN 55481 l
ATTH: MR. L. O. MAYE*
HUCLEAR SUPPORT SER. DEPT HRC LICENSEE SECONDARY REYHOLDS ELEC. & EHGR.CO.IHC.
P.O. BOX 14408 LAS VEGAS HV' 89814 DOE SECONDARY ATTH8 MR. ARDEH E. BICKER VT.YAHKEE HUCLEAR PWR, CORP.
TURHPIKE ROAD WESTRORD MA 09581 HRC LICENSEE SECONDARY ATTHs MR. ROBERT L. SMITH WESTINGHOUSE ELECTRIC CORP.
P.O. BOX 355 PITT5BUROH PA 15238 ATTH: MR. RONALD P. DIPIAZZA WATER REACTORS DIVISIGH HRC LICENSEE SECONDARY
= : -n_. _.._
N'.
WHO IS REGULATED SHIPPERS CARRIERS NRC DOT DOT STATE GOVERNMENTS AGREEMENT STATES L
2 u-m-
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- ~ - -
IBANSPORT SAFETY SilIPPERS CARRIERS 4
PACKAGE PACKAGE TRANSRORT llARDWARE OPERATION TRANSPORT
)
LONTROLS PREPARATION ROUTE PLACARDING DESIGN MONITORING SPEED SEGREGATION MANUFACTURE MARKING / LABELING VEHICLE CO-MINGLING MAINTENANCE DRIVER STOWAGE EXTERNAL CONTAMINATION DOSE RATE TIE-DOWNS k
t REGULATION OF RADI0 ACTIVE MATERIAL TRANSPORT POSTAL SERVICE EXEMPT QUANTITIES BY MAIL DOT INTER-STATE CARRIERS EXEMPT QUANTITIES TYPE A (NON-FISSILE)
LSA (TYPE A QUANTITIES)
TYPE B SPECIFICATION PACKAGES IMPORT SHIPMENTS DOE SHIPMENTS (NON-DEFENSE)
NRC TYPE A (FISSILE)
TYPE B PACKAGES LSA (TYPE B QUANTITIES)
STATE GOVERNMENTS -
INTRA-STATE CARRIERS AGREEMENT STATES JNTRA-STATESHIPMENTSBYSTATE LICENSEES LOCAL GOVERNMENTS /
BRIDGE, TUNNEL AUTHORITIES, ETC.-
ROUTING, PRE-DOTIFICATION, BANS, ETC.
m.._
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DOT /NRC MEMORANDUM 0F UNDERSTANDING DEVELOPMENT OF SAFETY STANDARDS ADOPTION OF SAFETY STANDARDS 1
PACKAGE REv!Ew INSPECTION AND ENFORCEMENT ACCIDENTS AND INCIDENTS NATIONAL COMPETENT AUTHORITY n,-
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DOT /NRC MOU DEVELOPMENT OF SAFETY STANDARDS QQI TYPE A PACKAGES LSA PACKAGES EXTERNAL RADI ATION LEVELS (ALL PACKAGES)
MARKING / LABELING (ALL' PACKAGES)
TIE-DOWNS LO AD I NG / UN-LO AD I NG / H AND L I NG / STO R A G E IRANSPORT CONTROLS FOR RADI ATION ' SAFETY VEHICLES / DRIVERS ALL OTHER EXCEPT THOSE SPECIFIED FOR THE NRC HRC (TYPE A FISSILE AND TYPE B PACKAGES)
MATERIALS CLOSURE DEv!CES STRUCTURAL INTEGRITY CRITICALITY CONTROL CONTAINMENT.0F MATERIAL SHIELDING INTERNAL PRESSURE INTERNAL CONTAMINATION INTERNAL HEAT QA
PACKAGE' APPROVAL DOT
. EXEMPT TYPE A (NON-FISSILE)
LSA SPECIFICATION CONTAINER PACKAGES OF FOREIGN CERTIFICATION PACKAGES FOR IMPORT / EXPORT TYPE A (FISSILE)
NRC TYPE B i
i
10 CFR PART 71 SUBPART A GENERAL PROVISIONS PURPOSE, SCOPE, DEFINITIONS, EXEMPTIONS, GENERAL LICENSES, ETC.
B LICENSE APPLICATIONS CONTENTS OF AN APPLICATION C
PACKAGE STANDARDS STANDARDS FOR STRUCTURAL AND CRITICALITY SAFETY UNDER NORMAL AND ACCIDENT CONDITIONS D
OPERATING PROCEDURES QA PROGRAM, PRELIMINARY AND ROUTINE DETERMINATIONS, REPORTS, RECORDS APPENDICES A
NORMAL CONDITIONS B
ACCIDENT CONDITIONS C
TRANSPORT GROUPS D
SPECIAL FORM E
QUALITY ASSURANCE
, - ~. ~, - -,,.,,, - - -
w e-*-
s - - - - --
~
10 CFR-PART 71 TEST CONDITIONS ACCEPTANCE STANDARDS GENERAL ALLOWABLE STRESSES (LIFTING AND TIE-DOWN' DEVICES)
NORMAL IRANSPORT ONTAINMEbT XTERNAL 10SE RATE UBCRITICAL NYPOTHETICAL ACCIDENT
[0NTAINMENT CONDITIONS EXTERNAL U0SE RATE buBCRITICAL
4 i
1 2
HORMAL CONDITIONS OF TRANSPORT APPENDIX A, 10 CFR 71 4
HEAT COLD
~
PRESSURE L
VIBRATION EACH TEST IS APPLIED SEPARATELY TO WATER SPRAY DETERMINE ITS EFFECT ON THE SHIPPING l
FREE DROP CONTAINER CORNER DROP PENETRATION COMPRESSION FOLLOWING TESTS, PACKAGES MUST:
PROVIDE _ CONTAINMENT OF MATERIAL MAINTAIN EXTERNAL RADIATION LEVELS WITHIN ALLOWABLE LIMITS MAINTAIN FISSILE CONTENTS IN SUB-CRITICAL CONDITION
~-
, -, - ~,,
IlYP0TilETICAL ACCIDENT CONDITIONS APPENDIX B, 10 CFR 71 hhR$hE IbbMU_khhk!!!C
)
)
1.
FREE DROP PACKAGE DROPPED FROM 30 FEET ORIENTED FOR MAXIMUM DAMAGE ESSENTIALLY UNYIELDING SURFACE l
2.
PUNCTURE CONTAINER DRQPPED FROM 40 INCHES ORIENTED FOR MAXIMUM DAMAGE ONTO b-INCH DIAMETER STEEL SHAFT i
3.
FIRE 14750F FOR 30 MINUTES 4.
IMMERSION COVERED BY 3 FEET OF WATER FOR 8 HOURS 1
FOLLOWING TESTS, PACKAGES MUST:
PROVIDE CONTAINMENT OF MATERIAL MAINTAIN EXTERNAL RADIATION LEVELS WITHIN ALLOWABLE LIMITS MAINTAIN FISSILE CONTENTS IN SUB-CRITICAL CONDITION m
.,-s
___________m____.____
b l
J OPERATING PROCEDURES IESTS BEFORE FIRST USE OF EACH PACKAGE TESTS BEFORE EACH USE OF EACH PACKAGE TESTS AT PERIODIC INTERVALS I
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QA REQUIREMENTS t
NRC APPROVED QA PLAN REQUIRED FOR TYPE B'AND TYPE A (FISSILE) PACKAGES 18 CRITERIA SIMILAR TO.PART 50, APPENDIX B QA PLANS COVER:
DESIGN FABRICATION ASSEMBLY IESTING MAINTENANCE REPAIR MODIFICATION USE
l TO OBTAIN AN NRC CERTIFICATE OF COMPLIANCE, APPLICANTS MUST:
PROVIDE ENGINEERING DRAWINGS OF THE PROPOSED DESIGN SPECIFY THE IYPE, QUANTITY, AND FORM 0F MATERIALS TO BE bHIPPED 3EMONSTRATE THAT THE PACKAGE WILL MEET IHE SAFETY STANDARDS
-OR NORMAL AND ACCIDENT CONDITIONS ESCRJ,BE A SET OF OPERATING PRQCEDURES FOR [HE 3
HAT MEET THE REPUIREMENTS OF 5UBPART D OF.0 C_ACKAGE
-R 71.
6 4
METHODS OF DEMONSTRATION 1
IEST 0F FULL-SCALE PROTOTYPE SCALE MODEL TEST e-ENGINEERING ANALYSES COMPARISON (ANALOGY) TO OTHER PACKAGE DESIGNS' COMBINATION OF ABOVE 4
i l
1 1
l daNUFACTURE AND USE OF PACKAGES NRC CERTIFICATES OF COMPLIANCE AUTHORIZES A SPECIFIC PACKAGE DESIGN SPECIFIES CONDITIONS FOR USE OF PACKAGE ANY NUMBER OF PACKAGES MAY BE FABRICATED TO THE AUTHORIZED DESIGN i
FABRICATION MUST BE IN ACCdRDANCEWITHBOTHIHECERTIFICATEOF 1
COMPLIANCE AND AN APPROVED QA PLAN LICtsSEES MAY USE ANY APPROVED DESIGN, PROVIDED:
REGISTERS WITH NRC
)
USE IN ACCORDANCE WITH CERTIFICATE AND 10 CFR PART 71, l
SUBPART D (OPERATING PROCEDURES)
FOLLOWS AN APPROVED QA PLAN 1
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4 PROGRM1 STATUS i
i l.
PRINCIPAL OBJECTIVE DEVELOP, ISSUE AND MAINTAIN REGULATIONS AND GUIDANCE FOR THE PACKAGING AND TRANS-j I
PORTATION OF RADIOACTIVE MATERIAL
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4 i
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2.
AREAS OF PRIMARY INTEREST A.
RISKS AND FNVIRONMENTAL IMPACTS FROM RN1 TRANSPORTATION B.
EMERGENCY RESPONSE TO TRANSPORTATION INCIDENTS C.
TRANSPORT WORKER EXPOSURE D.
QUALITY ASSURANCE IN FABRICATION, IESTING, USE MODIFICATION, REPAIR & MAINTENANCE OF RAM PACKAGING E.
COMPATABILITY WITH DOT AND IAEA REGULATIONS f
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PRINCIPAL TASKS A.
ASSESS RISKS & [NVIRONMENTAL IMPACTS o
NUREG 0170 0 URBAN STUDY o
NASH-1233 UPDATE o
SHIPMENT SURVEY 0
INCIDENT DATA COLLECTION AND ANALYSIS o
PKG. SURFACE CONTAMINATION LIMITS o
t!RC/ DOT / STATE SURVEILLANCE PROGRAM (SP) o WAS!! 12I18 UPDATE (NMSS) o LSA STUDY (MMSS) o MODAL STUDY (NllSS)
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8.
[MERGENCY RESPONSE 0 STATE / LOCAL GUIDANCE l
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- SURVEY OF STATE CAPABILITIES i
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- GUIDANCE TO STATES O
SHIPPER PLAN RULE AND 6UIDE i.
0 CRITICAL MASS PETITION f
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TRANSPORT IIORKER EXPOSURE j
0 TRANSPORT I!ORKER EXPOSURE STUDY.
i 0 ADVISE D0T D.
QUALITY ASSURANCE l
0 GUIDE FOR SPENT FUEL, !!LI.' AND ELUTONIUM l
0 GUIDE FOR I'ORMAL 3 SPECIAL FORM RAf1 5
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DOT /IAEA COMPATABILITY O
PART 71 REVISION O DOT ROUTING RULE F.
MISCELLANEOUS 0
PU AIR TRANSPORT REGULATION O
PKG. MONITORING ON P.ECEIPT REGULATION (20,205)
O PKG. RADI ATION LEVEL flEASUREMENT 6UIDE O
PxG. APPROVAL FORMAT 6UIDE
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l TRANSPORT OF RADIOACTIVE MATERIAL POTENTIAL HAZARDS
+
DIRECT RADIATION EXPOSURE i
CONTAMINATION OF PROPERTY INTERNAL RADIATION EXPOSURE 4
3 NUCLEAR CRITICALITY RESULTING IN dBOVE HAZARDS HEAT DAMAGE s
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RECOMMENDATIONS OF ICRP ON RADIOLOGICAL PROTECTION i
i, O GENETIC DOSE TO THE POPULATION -
170 MREM IN A YEAR
- O MEMBERS OF THE PUBLIC -
1 i
0.5 REM IN A YEAR
- O UNNECESSARY EXPOSURE BE AVOIDED -
l ANY EXPOSURE MUST BE JUSTIFIED O ALL DOSES BE KEPT AS LOW AS READILY ACHIEVABLE, ECONOMIC AND l
SOCIAL CONSIDERATIONS BEING TAKEN INTO ACCOUNT l
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- IN ADDITION TO THE DOSE FROM NATURAL BACKGROUND AND FROM l
MEDICAL PROCEDURES.
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PROTECTION IN TRANSPORTATION
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SHIELDING CONTAINMENT
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SPACING FO'R CRITICALITY CONTROL HEAT DISSIPATION I
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- 2. LIMITATION ON PACKAG'E CONTENTS l
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- 5. EMERGENCY PROCEDURES l
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V O L.1 puREG -0170 9
FINAL ENVIRONMENTAL STATEMENT ON THE TRANSPORTATION OF RADIOACTIVE MATERIAL BY AIR AND OTHER MODES i
Docket No. PR-71,73 (40 FR 23768)
December 1977 C
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3M
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Office of Standards Development
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U. S. Nuclear Regulatory Commission e
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Sul0WutY OF RADI0 ACTIVE MATERIAL 5 HIPPING AND ITS MAJOR RADIOLOGICAL IMACTS 1975 4'
Shipment Pachaces Curles TI per K11eenters LCF (normal)
LCF (acc)
Type per Year per Year Year per Year.
per Year Percent.
per Year Percent 5
3 3
-5 7.03 x 10 2.11 x 10 7.74 x 10 1.19 x 10' O.0077 0.6 5.78 x 10 g
List,te,d, 5
5 j-Medical 9.10 x 10 5.78 x 10'
, 6.43 x 10 1.12 x 10' O.616 52 6.11 x 10
13 Industrial 2.15 x 10 9.39 x 10 3.43 x 10 -
3.01 x 10 0.281 24 1.60 x 10'I 34 5
0 5
8 Fuel cycle 2.,04 x 10 5.32 x 10 5.69 x 10 2.09 x 10 0.104 9
1.85 x It'I 39 5
8 I
1 5
5 2.98 x 10' 3.22 x 10 0.182 15 6.17 x 10
11 0
Waste 1.52 x 10 2.68 x 10 TOTAL 2.19 x 10 5.44 x 10 4.54 x 10 2.64 x 10' 1.19 100 4.73 x 10'I 100 0
8 6
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i 1985 l
Lletted 1.83 x 10 5.50 x 10 2.02 x 10 -
3.11 x 10 0.020 0.7 1.51 x 10
1' i
0 3
0 8
0 I
0
~3 Medical 1.71 x 10 1.50 x 10 1.20 x 10 1.92 x 10' 1.17 38 ' '
1.51 x 10 9
f Industrial 5.63 x 10 2.47 x 10 8.79 x 10 8.84 x 10 0.676 22 4.49 x 10'3 27 5
I 5
8 0
7
~
~3 Fuel cycle 8.36 x 10 8.41 x 10' 2.46 x 10 7.16 x 10 0.469 15 7.08 x 10 4e 5
0 I
I
~3 Waste 6.27 x 10 1.11 x 10 1.23 x 10 1.33 x 10 0.752 24 '.' '
2.54 x 10 15 I
f 6
7
-2 TOTAL 5.57 x 10 S.45 x 10' 1.68 x 10 5.97 x 10' 3.06 108 1.66 x 10 100 l
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1 COST IN DAYS OF LIFE ASSOCIATED VITH VAlt10US ACTIVITIES (Ref. 3-19)
Cost in Days of Life Activity Living in city (rather than in 1800 country)
Remaining unmarried 1800 Smoking 1 pack of cigarettes 3000 per deV 500 Being 4.5 kg overweight 240 Using automobiles 10 1
170 area / year of radiation dose Transportatice of radioactive 0.030 saterial" Calculation based on an average of 0.5 ares per year to an average expued individual O
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- INTEGRATED POPULATICM DDSE AND EXPECTED LATENT CANCERS FROM CERTAIN CLASS VIII ACCIDENTS IN HIGH-DENSITY URBAN AREAS 1
Population Dose 1975 1985 1
Commitment i
Standard Shipment (person-reel Organ LCP Probability Probability l
^
Co-60 (315,000 C1) 284 whole body 0
1.02m10 2.55x10-10
-10
-10
- I' Po-210 (144 C1) 5.27al,0' lung 117 2.57x10 8.2x10 0
i Plutoniuse 3.15x10 /
lung /
(1.23 x 10 C1) 1.11x10 bone 147 1.06 1 ~ I 1.06 10*II 0
7 Spent fuel 1400/
whole body /
l (rail cask) 2.85m10' lung 1
1.8a10'I' 6.91a10
4 Spent fuel 215/
whole body /
(truck cask) 4450 lung 0
2.99s10 '
1.0x10 '
~
~
e 0
Recycle plutonium
- 1.59x10 /
lung /
0 0
-10 (6.19 x 10 C1) 5.6x10 bone 74*
0.0 2.24x10
- 1985 only.
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