ML20150D851

Forwards General DOE Requirements for Quality Assurance for Users of NRC-approved Type B Packaging.Requirements Are Imposed by Field Ofc Staffs Thru Language in Each Contract. W/Encl Erdam 0529 & 5201 & IMD 5001(Serial 19)

ML20150D851
Person / Time
Site:	07100203
Issue date:	06/30/1978
From:	Brobst W ENERGY, DEPT. OF
To:	Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 7812070106
Download: ML20150D851 (52)

Text

{{#Wiki_filter:,. I i . -. =* A q, DBUC mgn,, O RECENED 3-De artment of Energy C 2 2 NIO JUII 3 0 Washington, D.C. 20545 g 90 u. p q was k g ps /s. Mr. C. - E. MacDonald y g m g U. S. Nuclear Regulatory Commission - Q'O_1, ~ '... - Washington, D. C. 20555

Dear Mr. MacDonald:

During our June 7, 1978, discussion in your office about the quality assurance requirements for " users" of NRC' approved Type B packaging, we proposed to send 3 you the general requirements used for our DOE contractors. These requirements are defined in ERDAM 0529 and 5201 manual chapters. The appropriate sect 1ons of these chapters are enclosed. We are enclosing Interin Management Directive, IMD 5001 (Serial 19), which is a DOE directive to continue using specific ERDA chapters until they are superseded. The enclosed documents embody our DOE quality assurance plans. During the meeting it was stated that the generic plan for all DOE contractors will be acceptable to NRC to permit licensees to use DOE contractor's packaging and for our contractors to use NRC approved licensee's packaging. The quality assurance requirements spelled out in the manual chapter sections of EiwAM 0529 and 5201 are imposed by Field Office staffs through language in each contract. DOE is committed to follow QA requirements and safety standards for fissile and Type B packaging. I Finally, our Field Office staffs appraise the contrcctors in their performance of these instructions. They evaluate QA plans, review records, and make recommendations when necessary. Safety staff from Headquarters makes periodic appraisals of each Field Office's QA program. This meeting helped us to reco1ve some questions raised by your new quality ( assurance regulations. l - Sincerely, [ f kt-1k' Wifliam A Brobst, Chief ,q s gj Transportation Branch ~ !!O Division of Environmental H Control Technology l "q EnclosuresM j As stated g]'3 \\ l 781207010(o. C

/,[ i c, b.- i C1 a .FOnM EnDA 489 '\\c j C"y,',d8[01' UN'ITED STATES g s ENERGY RESEARCH AND DEVELOPMENT ADMifJISTRATIOTJ _ ERDA MANUAL TRANSMITTAL NOTICE j-l ]. . Chapter 0529 SAFETY STANDARDS FOR THE PACI' AGING OF FISSILE l AND OTif ER RADIO, ACTIVE MATERIALS SUPERSEDED: TRANSMITTEO: J Numbor Date N urnlmr ' Date 050'0714 TN 5 ( omplete). 6/14/73 0529 (comp ete) 12/21/76 l chapter Chapter . Page(s) Page(s) U (CO*P M ND Appendix __0529 (complete) 12/21/76 . Appendix I AD 0529 2 7/18/75 LAD 0529 3 9/11/75 REMARKS: % -) The chapter has been revised to: L 1. update organizational nomenclature. 2. Incorpopte instructions issued in 1975 through I AD Nos. 0529 2 and 0529 3. 3. rearradec subject matter in the chapter or transfer it to the appendix,in accordance with the format prescribed by l AD 0201 13. O l!!

SAFETY STANDARDS FOR Tile PACI' AGING OF FISSILE e AND OTilER R ADID ACTIVli M ATI:RI ALS ERDA Appendix 0520 l PART IV QUALITY ASSURANCE FROCEDURES FOR THE FABRICATION, / ASSEMBLY, AND TESTING OF OFFSITE SHIPPING CONTAINERS l A. ESTARI.tSHf. TENT Afl0 MAIN fEf'AfJCE OF 4. provide, as required by ERDAM 05D1, for at l l PROCEDURES least an annual audit of the ERDA con t ractors' programs to assess their l Each Deld ' office shall require lis contractors. to effectiveness. establish and maintain a quahty unurance program S. provide that quality assurance records are to: maintained in an'auditable. file during the 1. assuie that the requisite standards of quality service life of the container, 5 are met in the fabrication, assembly, and 6. provide for a method of determining that test,mg of each paci. age. packaginCs procured for use. from other-l 2. assure that packages in use continue to meet sources, including ERDA contractors and the sequisite standards of quality, subcontractors or from licensees, me'et the B. ELEf,'iENTS OF A QUALITY ASSURANCE establish acceptance entena in terms of l f 7. PROGRAF 4 measurable characteristics and the effects of appmpriate tests prescribed in annexes 1,2, The program shall consist of a formal system of and 4 and required in part lu, C. procedural and organizational arrangements which: 1. require that specine responsibilities be 8-Provide for a program of routine maintenance inspection and, where - .-i assigned to designated units (including those necessary, retesting to assure that reusable 6f the vendor, the fabricator, and the containers continue to meet the applicable contractor) for assuring speci0ed quality at all stages of construction. design standards. i w 2. designate c o des, standards, and 9. provide for required training, testing, and ) I specifications for materials. equipment, certification of manu fac turing and methods of fabrication, testing, and inspection personnel involved in special v., performance. processes, such as welding and 3. provide for quality control of materikts, nondestructive examination, and for the equipment, and services in instances where required certi0 cation of equipment and these have not already been established by procedures used in the performance of existing standards and speci0 cations. special processes. 4 l I r i 4 I '13 Approved: December 21,107('l i w- --_____x

r e DO R M E R O A.4 8 9 "Tg"s 3 UNITED STATES ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION ERDA MANUAL TRANSMITTAL NOTICE Appendix 5201 TRANSPORTATION OF PROPERTY (Handbook) .I SUPER 5EDEut TRANSMITTED: 4 j Number " Date Number Date 5200-1 TN Chapter Chapter w Page(s) Page(s) m _ 5201 (complete) 5201 (complete) 7/14/75 IAD 5201 1 8/29/72 IAD 5201-2 1/3/73 IAD 52013 3/1/73 IAD 52014 10/26/73 ) IAD 52015 12/30/74 _f REMARKS: ERDA appendix 5201 has been revised to: 1. retitle the appendix from " Transportation and Traffic Management" to " Transportation of Property," and restructure it into five major parts. 2. provide definitions which are pertinent to ERDAM 5201. 3. reflect the transfer of responsibility for the transportation program to the Division of Environmental Control Technology. 4 clarify and update existing provisions of appendix 5201. 5. add guidance on " Hazard Description and Classification" of radioactive materials and other dangerous articles. 6. make mandatory and periodic collection and maintenance of specified transportation and traffic data. 7. add a new section P. to part 111, regarding the use of military air transportation service to handle shipments for the account of the ERDA and its cost type contractors. 8 add a new section D to part V, on quality assurance for packages. 9. rescind IAD 52011, dated 8/29/72, and LAD's 52012,.3,-4, and 5. ERDA I AD 5201 1, dated 3/19/75, remains in effect. ) 1 l l

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s TRANSPORTATION OF PROPERTY - ERDA Appendix 5201 CONTENTS Page Port 111 Foreword....................................................................... 1 1 Definitions.................................................................. !! Sources of Radioactive Material Transportation Regulations and Related Material............ 3 A. Sources of Radioactive Material Transportation Regulations......................... 3 B. O t he r Rela te d M a te rial..................................................... 3 4 C. ANSI Standards.......................................................... 5 til Traffic Management........................................................... 5 A. Nego tiation for Ra tes o r Se rvices............................................. 5 B. Carrier Requests for Operating Authority C. Cornpliance with Transportation Laws or Regulations............................. 5 6 D. Consignment of Sidpments................................................. 6 E. Demurrage and Detention.................................................. 6 F. Freight Classification and item Description...................................... 7 G. Bills of Lading...........................................................

11. Equal Employment Opportunity Annotation of Shipping Documents..................

7 7 1. Exclusive Use of Vehicle.................................................... 9 7 J. Consolida tio n o f Shipmen ts.................................................. 7 K. Tra n s po r t a tion Da t a....................................................... L. Price Ande rson Ce r tifications................................................ 7 M. Shipments by American or Foreign Flag Carriers.................................. 8 N. Carrier and Government Exemptions (including Section 22 Quotations)................ 8 O. Use of Public Vehicles and Aircraft for Transportation of llazardous Materials........... 8 P. Use o f M ili t a ry Tr a n s po r t a tio n................................................ I1 Q. Insuring Shipments Against Loss. Damage, or Destruction While in Transit.............. I1 R. General Accounting Office Policy and Procedures................................. 11 13 IV Transportation Operations...................................................... 13 A. Waivers and Exemptions from Federal Regulations 13 D. Tie.Down Requirements.................................................... C. Ca r go Se c u ri t y............................................................ 13 D. Customs Clearance of import Shipments........................................ 15 E. Checking Vehicles and Packages for Damage and Leakage........................... 17 F. Packaging and Marking Goods for Transportation................................. 18 G. Labeling of liaiardous Materials Packages....................................... 18

11. Radiations levels-Extern J Surfaces of Vehicles..................................

20 21 V Packaging Operations......................................................... A. Standards................................................................ 21 21 H. Package Design Approval Procedures.................................. C. Processing of DOT Specification Container Designs............................... 28 29 D, Quality Assuraw for Package Fabrication, Maintenance, and Use E. Directory of Packagings for Transportation of Radioactive Materials.................. 29 9 F. Application for I AEA Competent Authority Certificates............................ 30 30 G. Test Programs............................................................ 1 Approved: July 14,1975

~ ERDA Appendix 5201 TRANSPORTATION OF PROPERTY Annexes A Title 41, Public Contracts and Property Management 31 B Actions Under National Emergency Conditions................................... 33 C Agreement Detween the General Manager and the Director of Regulation for Package Design Reviews 37 D Gui le for Preparing Safety Analysis Reports for Packaging.......................... 39 Exhibit ,3 2 .:4 1 Certificate of Compliance 43 1 7 g l Approved:' !aly 14, 1975 ti _ J,.

.~. TRANSPORTATION OF PROPERTY ERDA Appendix 5201 FOREWORD Tids appendix provides procedures andinformation for ERDA and ERDA contractor personnel in their conduct of transportation, traffic management, and radioactive and fissile material shipping container usage activities; supports ERDA's program requirements; and is consistent with international and national transportation policies. ERDA 1leadquarters and field offices are staffed with specialists in the areas covered by this cppendix. Program divisions are urged to use the knowledge and expertise of these staff members in their transportation planning and operations, i e l l l l 9 ill Approved: July 14,1975

3 TRANSPORTATION OF PROPERTY ERDA Appendix 5201 g PARTI DEFINITIONS For the purposes of ERDAM 5201, the following

7. Packaging -%e assembly of containers and any definitions apply:

other components attached thereto, including inner receptacles, absorbent material, supporting 1.ERDA Contractor-A prime contractor or structure, thermal insulation, and supplementary subcontrac' of the Energy Research and attached equipment. Developms.u Administration who is exempt from (or not subject to) licensing requirements

8. Package-The packaging, together with its of the Nuclear Regulatory Commission (NRC),.

radioactive contents, as presented for including 10 CFR Parts 71 and 73, transportation.

2. Cargo Security-%e physical protection against

9. Public Aircraft-Any aircraft which is used.

theft, pilferage, burglary, hijacking, sabotage, and exclusively by a Govemmental agency in carrying vandalism of cargo and vehicles in transit. (This out noncommercial operations, term includes " physical protection of cargo'.' and "transportalion safeguards.")

10. Public Vehicle-Any surface vehicle which is either owned by or leased to a Governmental 3, C a r rier-Any person engaged in the agency, and which rs operated by that agency.

transportation of passengers or property as a common, contract, or private carrier, or freight forwarder, as defined in the Interstate Commerce

11. Shipper-The person (or his agent) who tenders a Act, as amended; or the U.S. Postal Service; or shipment for transportativt. The term includes officers, agents, and employees of such carriers.

persons who: (a) prepare packages for shipment, f and (b) offer packages to a carrier for ~

4. Consignee-The person who is designated in the transportation.

shipping papers to receive the shipment.

12. Transport Vehicle-The conveyance (motor

5. Consignor-The person who executes the vehicle, rail car, aircraft, barge, or seagoing shipping papers, and who is named as such in the vessel) used for the transportation of property.

shipping papers. The consignor is in every case a Each cargo carrying body (trailer, van, boxcar,

shipper, freight container, barge, ship's hold, etc.) is a separate vehicle.

6. Exclusive use of vehicle-A service whereby a vehicle is assigned for the sole use of a specific

13. Property-Goods and materials, including nuclear consignor, loaded only by that consignor, and materials, shipped by or for the account of the unloaded only by the consignor or consignee.

ERDA. i 1 9 1 Approved: July 14,1975

TRANSPORTATION OF PROPERTY ERDA Appendix 5201 PART 11 SOURCES OF R ADIOACTIVE MAT 5 RIAL TRANSPORTATION REGULATIONS AND RELATED MATERIAL A. SOURCES OF RADIOACTIVE MATERIAL B. OTHER RELATED MATERIAL TR ANSPORTATION REGULATIONS Several private and Governmental agencies other than The principal sources of Federal regulations those listed in A.,above,have printed publications or pertaining to the transportation of radioactive and standards which either set forth certain of the above i ssile materials in interstate and foreign commerce regulations in full or in part, or provide guidance in are listed below. The regulations contain provisions connection with some facets of transportation of 1 for classification, packaging, marking, and labeling of nuclear materials. Publications applicable solely to packages of radioactive and fissile materials.They are foreign commerce are also available. These issued by three agencies and codified in the Code of publications are helpful for use in daily operations. It Federal Regulations: the U.S. Nuclear Regulatory should be understood, however, that some of these Commission; the U.S. Department of Transportation; publications are not complete restatements of the and the U.S.PostalService.These Federal regulations regulations applicable to interstate and/or foreign are codified and published in the Federal Register, commerce, and reference must be made to the Code and the Code of Federal Regulations (CFR). The of Federal Regulations (CFR) or other appropriate regulations of each agency are published separately, authority for the actual and complete requirements ' They may be purchased from the Superintendent of applicable to the packaging and transportation of D ocuments, U.S. Govermnent Printing Office, radioactive and fissile materials. Some of these Washington, D.C. 20402, publications, tariffs especially, are reissued and updated periodically. Some of these publications are 1. U.S. N uclear Regulatory Commission as follows: Regulations 1. " LATA Restricted Articles Regulations," published periodically by the Intemational a. 10 CFR 71, Packaging of Radioactive Air Transport Association,1155 Marsfield Material for Transport. Stree t, Montreal 113, Quebec, Canada, b. 10 CFR 73, Physical Protection of 2. " Regulations for the Safe Transportation of Special Nuclear Materialin Transit. Radioactive Materials, Safety Series No. 6," issued by the International Atomic Energy 2. U.S. Department of Transportation Agency; Kartner Ring 11. P.O. Box 590, Regulations A 1011 Vienna, Austria. 3. " Official Air Transport Restricted Articles a. 49 CFR 170189, llazardous Materials Tariff," Air Transport Association of Regulations. America; published periodically by Airline b. 14 CFR 103, Transportation of Tariff Publishers, Inc.,1825 K Street, NW., Dangerous Articles and Magnetized Washington, D.C. 20006. Materials. 4. " Hazardous Materials Regulations of the c. 46 CFR 146, Transportation or Storage Department of Transportation, including of Explosives or Other Dangerous Specifications for Shipping Containers," Articles or Substances and Combustible Graziano's Tariff No. 25; published Liquids Aboard Vessels, periodically by R. M. Graziano Tariff d. 49 CFR 85, Cargo Security Advisory Publishing Agent, Bureau of Explosives, Standards. Association of American Railroads,1920 L Street, NW., Washington, D.C. 20036, 3. U.S. Postal Service Regulations 5. " Department of Transportation Regulations for Governing Transportation of flazardous 39 CFR 123,(Regulations for Transport of Meials by Motor, Rail and Water, Radioactive Matter are published in U.S. Including S pecifications for Shipping Postal Service Publication No. 6.) Containers," Dangerous Articles Tariff No. i 3 Approved: July 14,1975 1-

9 + - 4 al ,ERDA Appendix 5201 - Part II. TRANSPORTATION OF PROPERTY s; 15; published periodically by American standard reflects agreement on the part of persons Trucking Associations, Inc.,1616 P Street, who - are substantially involved with the specific [ ~ NW., Washington',' D.C. 20036, subject matter. A standard is a guide to all those who

6. '" Shipping Radioactive Materials" (1971),

are involved with the particular subject. Adherence to Hf issued.by Bechtel Corporation, 50 Beale a standard should be helpful to all concerned. ' 41 Street, San Francisco, California 94119. $j 7. " Summary - of. Federal' Regulations for ANSI standards related to the transportation of Packaging and Transportation of Radioactive ' nuclear materials are as follows: T.g y 4 Materials," BRil/DMRE 71 1 (1971), U.S.- 1. ANSI N14.1-1971: Packaging of Uranium ,w Government. Printing Office, Washington, .2. ANSI N14.3-1973: Packaging : and Hexafluoride for Transport. MJ D.C. 20402, 8 " Transportation of Radioactive Materials," Transporta tion ' of. Radioactively ' $- ] issued by the Office.of flazardous Materials Contaminated Biological Materials.

33

in its OllM Newsletter dated February 1972, 3. ANSI N14.5-1974: Leakage Tests on Volume 11, Number 8. ' Copies may be, Packages for Shipment ' of.. Radioactive ] obtained from the Office of Ilazardous Materials. = Materials, U.S. Department of 4 ANSI N 14.10.1-1973: Administrative f 4 Transportation, Washington, D.C. 20590. Guide for Packaging and Transporting M. ,~ 9. "An. Index to the Hazardous Materials Radioactive Materials. ,j. 1 Regulations," Office ofilazardous Materials; 5. ANSI N14.10.2-1973: Administrative m: published by. U.S. Government Printing Guide for Obtaining Department of My ' 1 Office, Washington, D.C. 20402. Transportation Special Permits for Radioactive Material Shipments. -tPI. C. ANSI STANDARDS 6 ANSI N14 Guide: Administrative Guide for - - 4!=4 the Liability Aspects for Shipping Nuclear q ;i ~ The American National Standard Institute (ANSI) is Materials. working on and has published standards related to the 7. ANSI MH6.1-1968: Pictorial Markings for l' j ! transportation of radioactive materials. Such a Handling of Goods, d kI 1 g =. }g 91 4.. s y i 3I j -..i ; a!4i 1; e .l; -l, 'I l i

i. d.

. ej ) ~4,, \\ - Approved: July 14[1975~ j{. 4 4 I

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e 4 TRANSPORTATION OF PROPERTY ERDA Appendix 5201 PART lil . TRAFFIC MANAGEMENT l A. NEGOTIATION FOR RATES ON SERVICES the proposal to the Division of Environmental Control Technology for Relief from rates, classificatien rules, or carrier's review. Copies also should be fumished to regulations affecting shipments of viclear explosives those offices which might be interested in and radioactiva and fissile materials, regardless of the the proposed negotiations. tonnage. irnolved, which appear to warrant i adjustment shall be sought by negatiation through Upon receipt and review, interested offices es t ablished carrier - channels. (See ERDAPMR shall advise the proponent office and the 109-40.305 3 contained in annex A.) Similar Division of Environ men tal Control negotiations affecting all other commodities in . Technology of the extent of their interest j straight or mixed loads shall be handled in accordance and the desired degree of participation in the with the provisions of FPMR 101 40.305 3 and FPR negotiations. 1 19. If it develops that several field offices are 1. Content of Rate Proposals. Requests for interested, a coordinated proposal (with full r ljustments should include, where supporting data) must be forwarded by the appropriate, the followingjustifying factors: proponent office through the appropriate a. Description of commodity. channels to the Division of Environmental b. Value of packaged shipments and/or Control Technology for coordinating and released valuation, appropriate handling. c. Manner of shipment. d. Kind of container to be used. 3 Application,of Rates ur Services. Rates or e. Density per cubic foot. services obtained through negotiations shall 6 f. Size and shape of article. be applied to ERDA and ERDA contractor g. Susceptibility to damage, shipments where applicable, h. Average earload or truckload weight. I. Type of carrier equipment required. B. C ARRIER REQUESTS FOR OPERATING

j. Special services incident to shipment, AUTHORITY such as attendants, etc.

k. Estimated volume of movement. All participation in proceedings with the ICC or CAB 1. Length of haul, shall be under the advice of counsel. Subject to the

m. Regularity of movement (whether requirements of ERDA Chapter 0306, "ERDA constant or sporadic).

Participatica in Regulatory Proceedings," managers n. Name of origin and destination. of field of0ces may indicate a need for transportation o. Comparison of the proposed rate with service through submission of written statements to existing rates on the same commodity the regulatory agcacy concerned or by other within the same general territory or a appropriate procedures. A copy of each submission statement concerning the similarity of and supoorting testimany rnue be fntwarded to the the commodity to other commodities Division of Environmental Control Technology. (See on which rates exist, also ERDANMR 109 40.102 in annex A.) p. Statement of unreasonableness or inadequacy of existing rates or other C. COMPLI ANCE WITH TRANSPORTATION I tariff provisions. LAWS OR REGULATIONS q. Valuation on which existing rates are based. Shiprnents must be made in compliance with r. Statement as to competition with other appropriate internationa!, Federal (see Note below), modes of transportation; state, and local regulations, except as they may be 2. Procedures for 11andling Rate Requests. When it is believed that other field of0ces

• In the cue of state and local laws or regulations it

) would have an interest in a rate proposal, the may sometimes be necessary to assert the constitutional proponent Geld office shall furnish a copy of immunities of the FederalGovernment. 5 Approved: July 14,1975

ERDA Appendix S201 Q< Part!!! TRANSPORTATION OF PROPERTY { waived by. the cognizant regulatory authority, by the field oince manager to the ] pursuant to a determination by the field office manager of the need for such waiver for the effective appropriate regulatory agency. Requests for 3, conduct of the ERDAoperations, waMrs or exemptions from Federal laws l' and regulations must be forwarded by the field of0ce ruanagers to the Division of J Note: Shipments of hazardous materials by an Environmental Control Technology (ECT) ] agency of the Federal Government in its own for coordination and submission to the vehicle operated by its own employees are not appropriate regulatory agency. The Division g-considered to be in interstate commerce,and the of Naval Reactors may, at its option, make y De partment of Transportation's llazardous t Materials Regulations are not applicable to such direct contacts in this regard, keeping ECT 4 shipments. Shipments shall be made in a manner informed of any such actions. (See also part whPh would afford equivalerit protection of the IV, A.of this appendix.) gW public's healtL and safety as would compliance D. CONSIGNMENT OF SHIPMENTS with the DOT *c quiations.The DOT regulations -t; should be foliore Iwhere possible,as a matter of ] Comrnercial bills of lading or express receipts 3 ERDA policy. covering shipments made by or to ERDA contractors 4 + 1. Radioactive Materials and Other llazardous should provide for consignment of the shipments j Materials from or to either (1) the U.S. Energy Research and a Development Administration "in care of" the ERDA J contractor or (2) the ERDA contractor "foi the a. Federal and State Regulations. The United States Energy Research and Development - j regulations of the Department of Administration." Transportation, U.S. Postal Service, and H vi any state authorities which govern the E. DEMURRAGE AND DETENTION transportation of radioactive materials and other articles are applicable to both + To assure prompt release of carrier's equipment shippers and carriers of these materials. (particularly special capacity, heavy. duty, or other p@0y b. Local Regulations. ERDA shall comply equipment in short supply), and to avoid demurrage 1: with local regulations governing the and detention charges, a diligent effort must be made ] to load, unload, and release freight equipment within transportation of radioactive materials, except as indicated in footnote 1. the prescribed fee time Rail " average demurrage 3 agreements" should be entered into when the volume 3l 2. State and Local Size and Weight Limitations of rail traffic justifies such an arrangement. 9); for Ilighway Shipments. Motor carrier F. F R EIGHT CLASSlFICATION AND ITEM shipments shall conform to state and local DESCRIPTION ai laws, regulations, and ordinances relating to a weight and size limitations. No vehicular Freight classincation is an important factor in 1i j movement which exceeds any state's legal weight or size limitation shall be undertaken determining the charges which will be paid for 'l transportation of property. Reduced charges are over public highways unless prior permission often available in exceptions or commodity tariffs or jl is granted by the state concerned. ERDA or Section 22 tenders on shipment of specific i g ERDA contractor support of a carrier t requestmg such permission may be furnished commodities. False billing or classincation of freight only after a determination by the field office is prohibited by law. The Interstate Commerce Act prescribes fines and penalties (applicable to shippers manager that it is not practical to divide the and carriers) for such falsifications. load into smaller sizes or feasible to move

-l the tnaterial by any other means of Freight classification and item descriptions shall be transportation, consistent with the freight rate authority governing i

3. Wahcrs and Exemptions. When the effective the particular shipment.13 road descriptions which are not provided in tariffs (such as " building material") d conduct of ERDA operations requires shall not be used. Trade names may be used in deviaCon or specific exemption from state connection with published freight nomenclature -{ and local laws and regulations, request for when it is believed such use will clarify the proper g waivers and exemptions may be made direct classification. 1 Approved: July 14,1975 6 M i 1 a

ERDA Appendix 5201 TRANSPORTATION OF PROPERTY Part til Shippers' who offer radioactive materials or other advantageously consolidated, consideration shall be hazardous materials subject to the Department of given to: (1) established stopoff privileges for partial Transportation's regulations shall describe and' loading or 'mloading at intermediate locations, (2) classify these articles on shipping papers as prescribed including small lots in the same car or trailers with in Part 172 of the DOT's regulations. Persons who carload or truckload quantities, and (3) possibly using knowingly deliver radioactive or other hazardous freight forwarder service. Any opportunities for . i goods under a false or de:eptive description, marking, consolidation between offices should not be or other declaration are subject to fines and penalties overlooked. In the case of exclusive use of vehicle as set forth in the Transportation of Explosives Act service shipments, consolidation may not be j (18 U.S.C. 831835). appropriate. G. BILLS OF LADING K. TRANSPORTATION DATA. See Energy Research and Development Field offices and the Director, Division of Administration Property Management Regulation Administrative Services, will obtain, periodically.cnd 109 40.50 contained in annex A. furnish to the Division of !!nvironmental Control Technology such transportation and traffic data as Shipping papers must now be endorsed with, among will provide an effective management tool for other t hings, the applicable Department of identifying potential areas for improvement in Transportation (DOT) Special Permit number. With transportation operations. As a minimum, the the changeover from DOT approvals and Special following data will be maintained:. Permits to ERDA approvals and Certificates of 1. Total transportation cost. Compilance, shipping papers will need to be 2. Total tonnage (collect inbound and prepaid - referenced with the latter. For example, the words outbound). "Ce r tifica te of Compliance USA /5645 3/DLF 3. Number of shipments (carload, truckload less than earload, less than truckload, etc.) I (ERDA AL)" will need to be referenced instead of " DOT Special Permit 1234." 4. Man years and cost of traffic staffs. The data in I.,2., and 3., above, shallidentify mode H. EQUAL EMPLOYMENT OPPORTUNITY of transportation and major commodity groupings ANNOTATION OF SHIPPING DOCUMENTS within each mode. Reports shall be submitted annually, on a fiscal year basis, with reports to reach See ERDA.PMR 109.40.5003(d) and 190-40.5004(a) lleadquarters not later than 60 days after the end of contained in annex A. the fiscal year. Reports should not contain classified information. 1. EXCLUSIVE USE OF VEHICLE l L PRICE. ANDERSON CERTIFICATIONS Exclusive use of a vehicle shall be requested only when required (1) for security or safeguards reasons, Upon request of a carrier, the ERDA will(1) issue a (2) because of the nature of the commodity being certification to carriers that a shipment is covered by shipped, or (3) by specific provision in the ERDA a Price. Anderson Indemnity Agreement with an Certincate of Compliance, the DOT special permit, or ERDA contractor, or (2) notify them that the stdp. the regulations. Freight bills or bills of fading covering ment is not covered by ny such agreement. (See such shipments shall be annotated to indicate both ERDA PMR 109 40.5101 m annex A.) that exclusive use of vehicle was requested and was furnished by the carrier, in the event a carrier requests ERDA to issue a ce r tifica tion concerning the applicability of J. CONSOLIDATION OF SHIPMENTS Price Anderson Indemnity to a particular shipment, the following procedures will apply: Through appropriate material scheduling and loading, 1. If the shipment arises out of, or in the and considering nuclear criticality safety, radiological performance of contractual activity under a safety, safeguards requirements, security interest, contract which contains the standard program requirements, and other pertinent factors, contract nuclear hazards indemnity clause shipments should be consolidated into larger shipping (see ERDA.PR 9 7.5004-24), the manager of ) quantities or units whenever such arrangements will the field office or the head of the 5 result in transportation or administrative econondes. Ileadquarters division or office involved in determining whether separate shipments may be should use the following form of certincate: 7 Approved: July 14,1975 l r

ERDA Appendix 5201 r Part III ? TRANSPORTATION OF PROPERTY "This shipment is subject to the terms carrier' shall be used when shipments of. ERDA . and conditions In' the nuclear hazards classified matter or strategically important materials 7 I indemnity clause in ERDA Contract No, are involved (see ERDAM's 2401 and 2405). If a foreign Dag carrier is used because (1) the United FOR Tile ENERGY RESEARCII AND S ta tes flag carrier cannot meet the service DEVELOPMENT ADMINISTRATION requirements, or (2) the United States flag carrier g rates are disproportionately high, or (3) use of a Authorized Representative" foreign flag carrier would be in the best interest of

• • ?

~ 2. If it is determined that the shipment h not the. Government, 'an - explanatory statement q covered by

a. contract containing the supporting use of the foreign flag carrier shall be i

standard contract nuclear hazards indemnity included in the shipment file, clause, inquiry shall be made to the Director of the' appropriate Nuclear Regulatory N. CARRIER AND GOVERNMENT EXEMPTIONS

ay Commission Regional Office as to whether (INCLUDING SECTION 22 QUOTATIONS)

Q, or not such shipment is covered by an indemnity agreement between the ERDA (In Preparation.) ~j and a licensee of the Commission. Following i is a listing of such offlees. D. USE OF PUBLIC VEHICLES AND AIRCRAFT 4 FOR TRANSPORTATION OF HAZARDOUS l{: U.S. Nuclear Regulatory Commission MATERIALS Region I

j -

"*? 631 Park Avenue 1. Policy. It is the policy of the ERDA that 3 King of Prussia, Pennsylvania 19406 shipments of property, including radioactive materials and other hazardous materials,- M]r U.S. Nuclear Regulatory Commhslon which are carried on public vehicles and '9' 1 Region 11 aircraft shall be made in such a manner as to 230 Peachtree Street, NW., Suite 818 comply with the packaging safety standards ,Q g-Atlanta, Georgia 30303 in the NRC and DOT regulations just as ///( though thcse shipments were fully subject to fj U.S. Nuclear Regulatory Commission the packaging provisions of those regulations Q Region 111 (see ERDAM 0529), in cases where the -h 799 Roosevelt Road applicable packaging safety standards cannot d Glen Ellyn, Illinois 60137 be met in their entirety, the managers of' d field offices are authorized to grant approval U.S. Nuclear Regulatory Commission of alternatives or exceptions only in 9-Region IV P.O. Box 5039 accordance with the provisions of chapter WI Widte Settlement, Texas 76108 0529 034c and chapter 0550-034e. Such .l!.l. exemptions shall apply only in those cases a U.S. Nuclear Regulatory Commission where shipments are made either on public WI vehicles or aircraft in accordance with these .9 Region V provisions, or on commercial vehicles under 1900 N. California Blvd., Suite 202 Walnut Creek, California 94596 the National Security Exemption of 18 U.S.C. 832c. Shipments which do not fall ^j) M. SHIPMENTS BY AMERICAN OR FOREIGN under the National Security Exemption,and 1: which are made in for hlre service on 7-FLAG CARRIERS 2 commercial (nonpublic) vehicles or aircraft j. must either fully meet the safety standards j When both United States and foreign flag carriers of in the DOT regulations (49 CFR 170189 air or water cargo are available to perform the service and 390-397, and 14 CFR 103), or must be } q at the time and in the manner required, a United covered by a DOT Special Permit grantinga 4 States Gag carrier shall be used, unless the rates by waiver to some portion of those regulations. M the Un(ted States flag carriers are disproportionately Shipments carried on public vehicles or j high in comparison with those of available foreign aircraft are not subject to the provisions of =a flag carriers, or unless use of a foreign Dag carrier would otherwise be in the best interests of the the Interstate' Commerce Act (49 U.S.C. 11003), the Transportation of Explosives q] : . Government, Notwithstanding, a United States flag Act (18 U.S.C. 831-835), or the Federal j 71 Approved: July 14,1975' 8 M 1 . ~.xb

i ERDA Appendix 5201 TRANSPORTATION OF PROPERTY Part til Aviation Act (49 U.S.C.13011542). The and maintained either by the National Security Exemption in 18 U.S.C. employees of the ERDA or by 832c is inapplicable to shipments carried on employees of an ERDA contractor public vehicles or aircraft since the Act itself as under (1), above. The vehicles does not apply. See part IV, A.I., for policy are public vehicles, j guidance on the use of the National Security (3) An ERDA field office or an ERDA l Exemption, contractor engages the services of a l commercial carrier to transport an 2. Application of Definitions intersite shipment of classified l materials offsite, between National a. "Public Vehicle"-Any surface vehicle Laboratory X and National which is either owned by or leased to a Laboratory Y. The ERDA provides Governmental agency and which la escort cars driven by ERDA or operated by that agency. Interpretation contractor employees. The truck is of this definition has varied from time driven by an employee of the to time. In order that a vehicle (rail or c arrier. This is a commercial highway) may be considered as a public trucking operation involving vehicle, it must meet both (1) the for-hire carriage in which the conditions of either ownership or lease, operator of the truck is engaged in and (2) the condition of use by the a revenue producing operation.The Government in a nonrevenue. producing truck is a for. hire vehicle, not a operation. It is not sufficient for the public vehicle. transportation o pe ra tion to be (4) An ERDA owned semitrailer is " supervised" or " controlled" by the loaded with Government owned U.S. Government it must actually be a property by an ERDA contractor. I G ove r nment operation not falling A commercial carrier is engaged to y within the definitions of common, provide a tractor and driver to haul contract, or private carriers engaged in the se mitrailer from National i commerce, defined in Section 203(a) of Laboratory X to National the Interstate Commerce Act (49 U.S.C. Laboratory Y. This movement is a 1 510). &amples: c ommercial operation and the (1) Trucks and automobiles owned by carrier is engaged in a the ERDA, will thle vested in the revenue producing operation. The i G ove rnment, are operated by truck, including the semitrailer,is a contractors of the ERDA (such as for hire vehicle, not a public q Union Carbide at Otk Ridge, du vehicle. Pont at Savannah River, Sandia at (5) A special train is made up of ten Albuquerque, etc.). The vehicles are ERDA owned ATMX 500 series rail driven by contractor employees, cars and two ERDA owned escort acting as agents for the ERDA. This rail cars. A locomotive owned and transportation activity is anciliary operated by a rail carrier is used to to the primary function being pull this special train. The train carried out by the contractor-that crew is employed by the rail carrier, of performing research and These transportation activities are development. The contractor's revenue producing. None of the rail transportation activities are cars is a public vehicle, and the nonrevenue producing and the movement constitutes for hire contractor is not engaged in carriage. commerce. The vehicles are public (6) An ERDA owned rail car, along

vehicles, with an ERDA owned escort rail (2) The ERDA has leased cars and car containing ERDA employees,is trucks from a commercial vehicle turned over to a rail carrier for rental company, The vehicles are transportation from storage Site A f

assigned exclusively to the ERDA to storage Site B. The on a long term lease (six months or transportation services are being more). The vehicles are operated provided by a commercial rail 9 Approved: July 14,1975 ~

ERDA Appendix 5201 Part !!! TRAP"ORTATION OF PROPERTY carrier, who ' is engaged in a under contractual obligation to revenue producing operation. operate the aircraft only for Neither car is a public vehicle, and Governmental uses. The aircraft is a the movement constitutes for hire public aircraft. carriage. (4) An aircraft is operated by an air carrier under contract with the b. "Public Aircraft"-Any aircraft which is ERDA for routine daily shuttle used exclusively -by a Government fligh t s between National agency in carrying out noncommercial Laboratory X and National operations. 'Ihe ownership of the Laboratory Y. On some of the daily aircraft is not a factor in determining flights, only Government freight whether the aircraft is to be considered and official ERDA or other ,;l a public aircraft, which is not subject to Government passengers are carried. the regulations of the Federal /.viation On other daily flights, revenue Administration of the DOT. The term passengers (e.g., dependents, "public aircraft" is also defined in the vendors) are carried as an DOT Act (49 U.S.C.1301[30}) as authorized contractual service to follows: those passengers due to the "'Public aircraft' means an aircraft remoteness of National Laboratory used exclusively in the service of Y. Such alternative or optional use - any government or of any political of the aircraft, or of mixed 4 subdivision thereof, including the Government and commercial government of any State, Territory, shipments on the same aircraft, is or possession of the United States, deemed to be air commerce. The or the District of Columbia, but not aircraft is a civil aircraft, not a including any government owned public aircraft, even while aircraft engaged in carrying persons empioyed for Government ng l or property for commercial shipments or carriage of purposes." Government shipments or carriage Unlike surface vehicles, the application of G overnment employees on of the term "public aircraft" depends official business. solely on the exclusivity of the use of (5) An aircraft is operated by an air < the aircraft in the service of the carrier under contract with the Government, and not on the identity of ERDA for occasional shipments of its owner. Examples: G overnment property between i (1) ERDA-owned aircraft (C 54, F 27, National Lab ora tory X and Fil 227) are operated by a National Laboratory Y. The commercial air carrier. The aircraft contract permits use of the aircraft are used exclusively in the service for commercial purposes when it is of the Government. The carrier is not engaged under the contract engaged in a revenue-producing with ERDA. The aircraft is a civil [ operation in air commerce. The aircraft, not a public aircraft, even aircraft are public aircraft. while employed for Government (2) An, aircraft owned by an alt carrier shipments, liowever, if the aircraft has been assigned to exclusive use was modified specifically to for Government shipments under a accomodate ERDA uses and is, in contract which requires that the fact, not operated for other than aircraft be reserved for exclusive-ERDA purposes, the aircraft is a ( use of the Government during the public aircraft. life of the contract. The aircraft is a public aircraft. 3. Interpretations. It is the responsibility of the (3) The same aircraft described in (2), program division director or field office above, is also operated by the air manager to determine whether a vehicle or carrier under contracts with several aircraft is public or for hire. The guidelines ? other Government agencies which above shall be used in making the decision. l' 4 permit such use, but the carrier is - Doubtful cases should be referred to the a I Q . Approved: ' July 14,1975 10 d a..

-_ m II.. W. !t ERDA Appendix 5201 lL i h TRANSPORTATION OF PROPERTY ?pl Part III Director, Division of Environmental Control who has operational responsibility-for ?$ ! Technology, who will obtain the necessary delivery and pickup of material to and from !l interpretation. from the appropriate .6. Freight description of material. j' airport. authority,

7. Number of pieces and weight and cubic P.

USE OF MILITARY TRANSPORTATION measurement of each piece of shipment.

8. Available date for shipment.

Conditions and procedures which are pertinent to the

9. Due date at destination.

use of military transportation service to handle

10. Specific name and address and fund citation shipments for the account of ERDA and its (if appropriate) for direct billing purposes, contractors are outlined below. These procedures are In the case of shipments in which ERDA has not applicable to shipments of the Division of Naval Programmatic interest (official concern) but which Reactors nor to shipments of nuclear explosives and are rnade by other than ERDA or an ERDA components within the purview of the Director, contractor, the field office will furnish the above Division of Military Application; existing procedures information, as well as certification that furnishing p

of the Divisions of Naval Reactors and Military such transportation is in the nationalinterest, and the d Application will remain in effect in these instances. name of the nongovernmental agency, company, or 0 individual who will be responsible for reimbursing Use of DOD's transportation systems shall be in DOD for the tn,sportation service, @g accordance with DOD regulations. DOD will handle ERDA and ERDA contractors' shipments when the The Transportation Branch, ECT, will process the 't i transpo-tation to be furnished is of official concern request for transportation service with DOD, except p to, and is to be paid for (directly, or by for activities in the naval reactors and nuclear n reimbursement to the contractor) by ERDA. weapons programs. l jj Shipments in which ERDA has programmatic interest (of0cial concern) but which are to be made by other Q. INSURING SHIPMENTS AGAINST LOSS, 7 than ERDA or its contractors, may also be handled DAMAGE, OR DESTRUCTION WHILE IN y by DOD if ERDA certifies that furnishing such TRANSIT j transportation :s in the national interest. The J f 0 foregoing is contingent upon a situation in which Consistent with the Government's selfinsurance commercial t ransportation is neither readily policy, funds shall not be expended to insure }ipi obtainable or satisfactorily capable' of meeting property against loss, damage, or destruction while in program requirements. transit. Q h Except in programs of the Divisions of Naval In cases where rates published in governing tariffs are h Reactors and Military Application, arrangements for dependent upon, and vary with, the declared or M@ obtaining military air transportation service shall be released valuation of the property being shipped, bills made through the Division of Environmental Control of lading shall not have entered on them the value of Technology (ECT), pursuant to (1) certification by the property being shipped. K the appropriate program division that furnishing such y transportation is in the national interest, and (2) This qualification does not apply to circumstances j' determination that commercial transportation is not under which carriers' tariffs provide different rates or p readily obtainable or satisfactorily capable of meeting ratings based on released valuation on particular L, program requirements. shipments. Under such conditions, notations will be ,g made on bills of lading to the effect that shipments The following information must be furnished when are released to the maximum value applicable to the such transportation assistance is required. lowest applicable published rate or classification rating. '7 For ERDA and ERDA cost type contractor shipments: R. GENERAL ACCOUNTING OFFICE POLICY

l. Consignor, AND PROCEDURES

2. Point of Origin,

,4. Destination Point, The authorities, responsibilities, and functions of the L 3, Consignee, General Accounting Office (G AO) insofar as domestic ,3l S. Name and offlee and home telephone and foreign freight transportation servic'es furnished l I numbers of person,at origin and destination, for the account of the United States are reflected in i1 Approved: July 14,1975 d n, I

1 ') !ERDA' Appendix 5201' Part !!! - TRANSPORTATION OF PROPERTY [g;-'! Title 5-Transportation, General. Accounting Office transportation activities. ERDA contractor activities Policy and Procedures Manuall'for. Guidance of ' related to freight transportation services for the - Federal Agencies, account of or on behalf of the Energy Research and Development Administration shall,' unless expressly. The policy and proceduralInformation contained in waived by G AO, be consistent with the G AO's policy. the GAO manual are applicable. to direct ERDA and procedures. ' ~ ) h i ZI (6): 4 4 i 1 A i Approved:' July l4,1975} ' . I'2 ~ ...o c-s .-..i,.

[k j di !M ' TRANSPORTATION OF PROPERTY. ERDA Appendix 5201 g - i(e PART IV 42 TRANSPORTATION OPERATIONS A. WAIVERS AND EXEMPTIONS FROM. shipment is tendered and the FEl)ERAl REGULATIONS express receipt or shipping - document must include the 1. National Security Exemption. -(in statement " A RhlED GUARD preparation.) SERVICE REQUESTED." 2. DOT Special Permits. (In preparation.) (3) Armed Surveillance S e rvice. Shipments will be transported B. TIE DOWN REQUIREMENTS under person to person tally. and signature by armed employees of (in Preparation.) .the Express Company - regularly assigned to protecting traf0c in p C. CARGO SECURITY general, except while shipment is in d the sealed express vehicle. h I. General. The term " protective services" as O used in this part means measures taken by b. REA Air Express y commercial carriers upon request to provide bj' protection for shipments, which is in (1) Security Signature Service, addition to the protection furnished under Shipments will be handled under the requirements of normal common carrier person to-person signature from activity. (See ERDAM 2401, " Physical time of receipt at origin to delivery d Protection of Classified hiatter and at destination, except that no o g information," and ERDAh! 2405," Physical receipt will be secured from the Fi f y Protection of Special Nuclear hlaterial," for flight crew or attendants additional information regarding degree of immediately in charge of the protection for property in transit.) aircraft on which shipments are l j being transported. Request for this 2 Type of Services Available. The following service must be made at the time pro te c tive services generally may be shipments are tendered,and the Air obtained from common carriers: Express Receipt must include the s t a t e m e n t, " SECURITY a. REA Express (Surface) SIGN ATU RE SERVICE i REQUIRED." d-(1) Protective Signat ure Service. Shipments will be handled under (2) Armed Guard Protective Security person to-person signature from Service. Shipments will be handled i time of receipt at origin to delivery and guarded under person to-person P h at destination. Request for this signature by armed employees of service must be made at the time the express company, ogularly

l shipments are tendered and the assigned to protecting traffic in l

express' receipt must include the general from time of receipt at statement ' PROTECTIVE origin to delivery at destination, S1GN ATURE SERVICE except while shipment is aboard the REQU ESTED." aircraft. Shipments will be loaded by airline e mployees, under (2) Armed Guard Service. Shipments observation of the Express will be guarded by ' armed Company's armed guard, in the employees of the Express Company baggage or cargo compartment of 4-assigned exclusively to guard such the aircraft which is not accessible shipment, except while, it is in to any person aboard during the j transit. Request for this service period the aircraft is in flight. A L must be made prior to the time the shipment will be under continuous ,,l ml 13 Approved: July 14,1975

i a,

mi

9 s ERDA Appendix 5201 Part IV - TRANSPORTATION OF PROPERTY /7(I surveillance of the armed guard:(1) f. U.S. Mail. The various classes of mail, from the time it is picked up by special protective services available, and REA Express until it is loaded in an instructions for using them,are set forth aircraft and the aircraft has in Appendix 0255," Mail Management." departed from the ramp;(2)during the course of transfer between 3. Requirements for the Security of Materials aircrafts at transfer points and until in Transit the connecting flight has departed from the ramp; (3) at scheduled a. The principal hazards to the security of intermediate stops short of final materials in transit are espionage, destination during the entire time s ab o tage, collision, theft, damage, the aircraft is on the ground during improper routing, and misdelivery. such stops; and (4) from the time b. In addition to the requirements of this of unloading from the aircraft until appendix, shipments of classified delivery to consignee. Request for ma te rials, and unclassified special this service must be made prior to nuclear materials, must also meet the l the time the shipment is tendered, applicable cequirements of ERDAM's and the alt express receipt must 2401 and 2405. include the statement, " ARMED c. Shipments of other high-value materials, GUARD PROTECTIVE not covered under ERDAM's 2401 or I SECUR1TY S E R VICE 2405, must be made in a manner which REQUESTED." will provide cargo security controls commensurate with their value. These c. Airlines materials include items which have a l high strategic, intrinsic, or operational } (1) Signature Service. Some airlines value, and which must be delivered in a s provide person.to person tally and timely manner. h signature while in the custody of d. Where practicable, the number of l the airlines. Individual high-value items of cargo to be tendered for transportation should (2) ERDA Armed Courier Service. be reduced by consolidating individual ERDA shipment c o urle rs packages into larger shipment units, accompanying the cargo will be giving due regard to nuclear criticality carried by some airlines under safety limits. The following are conditions speelned in their tariffs. exaaplea of acceptable methods of I consolidation: d. Motor Carriers (1) Palletization and banding. (2) Crating. (1) Seated Van Service, liovides for (3) Overpacking in freight contahier of I sealing the van or closed truck at a suitable size. point of origin. e. Shippers shall ascertain, prior to 3 shipment of high value materials, that (2) Exclusive Use of Vehicle. Service the required protective services can, in whereby a vehicle is assigned for fact, be provided continuously for the the sole use of specific consignor, shipment until receipt by the consignee, loaded only by the consignor, and f. Care should be taken to make certain unloaded only by the cenrignor or that classified information is not consignee. Exclusive use may also revealed on shipping documents or on include sealed van provisions. labels on packages which ate used pursuant to the DOT's llazardous c. Rall Carriers Materials Regulations. Appropriate freight descriptions and procedures (1) Sealed Railroad Car Service. should be worked ow with interested Provides for the sealing of freight carriers which are commensurate with /N g)g cars at point of origin with railroad the sensitive nature of the shipment and f or ERDA seals, which will afford an equitable return to Approved: July 14,1975 14 A

h L i-ERDA Appendix 5201 TRANSPORTATION OF PRTE ITY Part IV 3 j the carrier for the services performed. the case to the Director. Division of L (See also A.I., above.) Environmental Control Technology, for appropriate handling, with an information 4. Endorsement on Bills of lading for Rail copy to the Director, Division of Safeguards Shipments and Security. a. Freight Service. For those shipmsnts 6. C:.rgo Security Advisory Standards. The ~ requiring the use of shipment escort following documents provide general I. i i personnel, one bill of lading may be guidance in the field of cargo security: I-prepared for both the shipment and the transportation of the escort pc.sonnst. a. Guidelines for the Physical Security of in such cases, the number of shipment Cargo, May 1972, DOT P 5200.2. personnel shall be shown and the Superintendent of Documents, U.S. following notation placed directly Government P rin ting O f fice, below the number: Washington, D.C. 20402. Catalog " Carriers will make collectioit by Number TD 1.8:C19. 5.40 per copy,70 g[ filing a single bill covering freight p. and seivice charges for the carriage of attendants." A comprehe, listing of cargo theft This is not to preclude, where prevention tr- .res intended to assist a ppropriate, the use of TR's in transport management in proviumg transportalion of escort developing at. e4 cctive security system. h personnel. H b. Cargo Security llandbook for Shippers g b. l' asse n ge r Service. Carriers have and Receivers, September 1972, DOT concurred in an arrangement whereby P 5 2 00.5. S u p e rin tendent of Government-owned shipment pennnel Documents, U.S. Government Printing cars "deadbaded" in passenger train Of0ce, Washington, D.C. 20402. Stock j service, with or without shipment Number 5000-00059. 5.25 per copy,33 h personnel, rnav move on a bill of lading p. E containing thw '. orsement,"This car i* to move in passenger train service " The Guidme and assistance for shippers h car may Cso contain certain " training and .r. ivers in the development of a h material" which carriers have agreed by carro v i urity program. H Section 22 Quotation to transport under the same rates as are applicable to c. Cargo Security Equipment Applications [ Military Impedimenta. Such hills of G:M., June 1, 1972. Office of f ladug should be endorwd " Training Transportation Security, TS A.63, g Material; passe n ger train service Department of Transportation, required." Washington, D.C. 20590. Limited quantity only. No charge,68 p. [ 5. Failure of Carriers to Pronle Protectivr y Serr' :s. When the protective service A partialinventory of available security 9 by the, shipper either are not rquipment and systems, for application ... ' s, srv u provo..:d by the carrier, or are inadvquate or in the prevention of cargo theft. unsatisfactory, every effort should be made to resolve the matter by local negotiations D. CUSTOMS CLEARANCE OF I MPORT betweca the carrier and the ERDA office or SHIPMENTS ERDA contractor noticing the deficiency,if the latter, the FRDA of0cc concerned must 1. General. This part outlines the procedures be kept currently informed and should necessary in connection with customs assist, upon request,in the negotiations with clearance of ERDA importations. the carrier, if, in a particular instance, the remedial action by the carrier is not 2. Entry of Source, Special Nuclear, g s tisfactory to the responsible Geld of0cc By 8%dat, and Other Materials b manager, he will send a written summary of 15 Approved: July 14,1975 h R

o ~ CRDA Appendix 5201' Part IV TRANSPORTATION OF PROPERTY i a. Determination of Dutlable Status. nake special arrangements with the Articles imported !nto the United States U.S. Customs Service and Bureau of are classified under the provisions of the the Census. In such cases, the Tariff Schedules of the United States as Division of Environmental Control being duty free or subject to the Technology will require all available payment of respective rates of duty, pertinent information, including Because of the numerous changes which commodity description, country of have been and are being made in the origin, date of departure from schedules since the Tariff Act ' ecame origin port, port of entry, and name o effective, the U.S. Tariff Commission of carriers. Activities involving the periodically issues, for the purpose of United Kingdom Cooperation convenience and clarity, a publication authorized pursuant to Sections entitled the Tariff Schedules of the 1446. and c. of the Atomic Energy Uni:ed States Annotated from which Act will be processed by the may be determined the current dutiable Director, Division of Military status of imported merchandise, it.may Application, be obtained from the Superintendent of Documents, Gove mment Printing c. Duty. Free Imports. Thorium, uranium Office, Washington, D.C. 20 402. (regardless of enrichm t), plutonium, and use fully radioactive chemical b. Showing Descriptim and Value on Customs Documents elements, compounds, and isotopes, in the forms which these materials normally might be expected to enter the (1) General. The description of U.S., are classified as duty free in the com modities on shipping and Tariff Schedules, and additional c u s t oms documents should duty. free certification usually is not conform to commodity descriptions provided in the Tariff necessary, n Y Schedules of the United States; otherwise, clearance may be Other materials also may be imported delayed by the U.S. Customs int the U.S. free of duty; for example, Service. U.S. appraising officers are scientific instruments which will be required by law to establish a value returned to :ountry of origin. for imported goods. The tn.e purchase > : Ice (including terms of The Tariff Schedules should be sale) shall be shown by the specifically consulted in individual Importer r.nd, where possible, the

cases, current market value at the time of export from the country of d.

Certification Procedure. The Custom j exportation. It is essential that a Regulations (19 CFR 10.104[cj [3]) nnecific value be declared on all provide a certification procedure in WDA importations. The importer confouaity with tha requirements of isible for entering the the Tariff Ciassification Act of 1962 .JHe at the appropriate (Public Law 87456, Title Ill, Section and is not bound by any 303(e), May 24,1962, 76 Stat 78). umation secured from the Requirements for (a) information 'aiser. pertaining to a " blanket" certification, or (b) additional ce r tifica tion artations With - Security arrangements, should be referred to the est. When it is necessary for Division of Environmental Control arity reasons to concealidentity Technology which,in coope:ation with or prevent publication ' of import the O f fice of the Assistant sta tistics covering commodities Administrator for International Affairs, being entered, the Division of acts as the ERDA liaison with the U.S. En vir on me n t a1 Control Customs Service, Department of the Technology, upon request, will Treasury. Approved: July 14,1975 16

i-5. ERDA Appendix 5201 l TRANSPORTATION OF PROPERTY Part IV i 3. Sources of Customs Information. contaminated. the delivering carrier and i Regulations promulgated by the U.S. all intermediate carriers shall be so l Customs Service are published in Title 19 of notified immediately so that potentially j tiie Code of Federal Regulations. A booklet contaminated vehicles can be withdrawn entitled " Exporting to the United States," from service and checked. Loading outlines Customs Service requirements and docks and terminals through which the i may be obtained from the Superintendent of package passed in transit shall also be Documents, Government Printing Office, checked. Vehicles on site should be Washington, D.C. 20402. detained by the ERDA consignee until checked and decon taminated if E. CHECKING VEHICLES AND PACKAGES FOR necessary. The carriers are responsible DAMAGE AND LEAKAGE for arranging for contamination checks on intransit docks and terminals. s Good practice dictates that packages of hazardous Additional reporting requirements are materials are inspected promptly upon receipt for specified in ERDAM 0502. damage or other evidence of possible leakages to l' assure that any potential public exposure to 2. flazardous Materials Con tamination. j l contamination will be identined and appropriate Monitoring and decontamination of a action can be taken. He following procedures have commercial carrier's vehicles, and of his been developed for this purpose: terminal facilities contaminated by i hazardous material during transportation, 1. Early Pickup and Monitoring ere the responsibility of the carrier and/or j the shipper as may be provided by special a. The procedures in b., c., and d., below, agreements between the carrier and the i are not req uired for shipments shipper. The ERDA consignee is responsible censisting solely of packages which (1) only for monitoring and decontamination at 4, are not labeled with a DOT hazardous his own facility but these activities may j m a te rials label, (2) conten only include the carrier's vehicle,if necessary for radioactive gases, or (3) contain only the protection of health and safety. When l special form radioactive materials. radioactive material is involved, the carrier Jl 1 b. All shipments of hazardous materials may request ERDA radiological emergency received from carriers shall be promptly advice and assistance in evaluating the 3 and carefully inspected for damage and possibility that other transportation vehicles, l, leakage after they are delivered by the terminals, intermediate carriers or places l carrier, and, if practicable, before the en rou'e may have been contaminated. The delivery truck drives away. Where the ERDA contignee may request and/or initiate i ERDA consignee is responsible for radiological emergency assistance if he picking up the shipment from the believes it is needed for the protection of the i, carrier's termir.al facility, the packages public health and safety. i e sha!) be picked up as expeditiously as possible after notification by the carrier 3. DOT Reporting Requirement. Carriers are ofits arrival.md checked for leakage. responsible for reporting hazardous materials c. Any packy of hazardous material leakages, or suspected ra dioac tive suspected to t - Emaged or leaking shall contamination, to the DOT in accordance be checked for external contamination with 49 CFR 171.15 and 171.16. The en surfaces. If the package is found to ERDA consignee is responsible for providing be externally contaminated, and,in the the carrier the information necessary for him

)

case of radioactive materials, above the to make that report. ERDA consignees shall "signincant removable contamination" request a copy of the DOT report from the limits specified in 49 CFR 173.397, it carrier. If such a copy is not received by the - s ' will be assumed that the delivering consignee within 15 days, the consignee shall vehicle and areas in which the package submit a report to the DOT. A copy of the was loaded, unloaded, or stor'ed are also report to DOT must be sent to the Director, I contamina:ed. Division of Operational Safety, by the 4 d. If it is known, assumed, or suspected ERDA consignee. ERDA consignees are also that ' the delivering vehicle is required to report accidents and incidents s 17 Approved: July 14,1975 g

ERDA Appendix 5201 Part IV TRANSPORTATION OF PROPERTY ~ involving ERDA shipments to' ERDA G. LABELING OF HAZARDOUS MATERIALS licadquarters under ERDAM 0502. PACKAGES Generally, carrier personnel involved in a 1. Proper labeling of packages of hazardous repo: table accident will also notify their materials (including radioactive materials) is own supervisory personnel. local police, a continuing problem, particularly for fire, or other emergency officials are notified packages which are transported on open-top as necessary. The carrier's procedures usually vehicles, or which are held in open storage require that both the consignor and the for long periods of time prior to shipment. consignee also be notified. When notified, Exposure to the weather or rough handling ERDA offices or contractors should assist in transit can cause labels to become the carriers as rauch as possible in this obliterated or cause them to come loose regard. from the package surface. 2. Labels chould be of such quality and applied The carriers may also request assistance from in such a manner as to assure that they will the ERDA in how to " manage" a hazardous survive the normal handling and exposure to materials incident. Local ERDA emergency weather that may be encountered during the response plans and procedures should transport cycle. Local procedures thould include provisions for accommodating provide for adequate and appropriate routine " clean up" and public relations labeling of packages, and minimize the situations. possibility of defacement or loss oflabels in - transit. This can be accomplished in various F. PACKAGING AND MARKING GOODS FOR ways, including: TRANSPORTATION Using a good, high quality adhesive. a. Properly preparing goods for transportation is a duty Pressure sensitive labels, with peel off which a shipper owes to himself, to the receiver of backing, are more expensive than the standard " issue" label, but are very p the goods, and to the carriers which serve them. durable, and will stick to almost Except for those goods which can be shipped in bulk

anything, or loose, goods should be securely placed in b.

Covering labels with transparent tape. packaging of sufficiently substantial construction to withstand the ordinary hazards of transportation. Spraying labels with clear acrylic spray c. paint. Ik>th packaged and loose goods should be so marked d. Using a plastic protector or permanent as to assure prompt and correct delivery in good label holder. 3 order. If goods are properly packaged, and errectly, 3. The specific procedures to be followed legibly, and durably marked, much is accomplished should be responsive to the needs of the toward expediting their movement and assuring good shipping facility and the specific types of order delivery. packages generally being shipped. l Minimum packaging and marking requirements for 4. Use of " Empty" Labels goods in transportation are contained in the "Freiaht Cla ssifica tion" of the various modes of a. The Department of Transportation transportation. For hazardous materials, also see 40 regulations (49 CFR 173.29(e) and (f), CFR 173.401 through 173.430. More detailed guidance regarding packaging and marking of specific and 173.402(a)(12) require that any items may be developed locally as necewy. Two packaging or accessory which has been used for the shipment of radioactive additional references which may be u & n this ma t e rials, which contains residual regard are: internal radioactive contamination, and 1. RDT Standard F 7-2T, February 1969, which is shipped as empty, must be " Preparation for Scaling, Packaging, Packing. securely closed and an " EMPTY" label and Maiking of Components for Shipment (49 CFR 173.420) affixed. Any such and Storage." item must have all previously used 2. RDT Standara F 8-6T, August 1972, " r a d io ac tive" I::bels removed, "lloisting and Rigging of Critical obliterated, or completely covered by = Components and Related Equipment." an " EMPTY" label, unless in a closed q J, vehicle under exclusive use conditions. Approved: July 14,1975 18 d

en ERDA Appendix 5201 TRANSPORTATION OF PROPERTY Part IV b. If such a packaging has a radiationlevel (2) Internally contaminated casks. of more than 0.5 mrem /hr. at its Under 49 CFR 173.29(e), there is external surface, and contains either (1) no specified upper limit to the radioactive materials (as residual amount of radioactivity that may contents or as contamination)in excess be in the cask as residual activity. of the "small quantities" specified in 49 Ilowever, it should be assumed that l CFR 173.391(a), or (2) fissile " residual in ternal radioactive t radioactive materials (such as UF, contamination" excludes any l " heel") in excess of the amounts _ " usable product," and may not i exempted in 49 CFR 173.396(a), then exceed the " exempt" limits of 49 l the packaging may not be shipped as CFR 173.391(a). As long as those j " empty" for purposes of 49 CFR 172.5, two qualifications are met, and the l 173.29(c) and (f), or 173.427. It must external surface dose rate is not l instead be classined as a " radioactive over 0.5 mren/hr., the following i materials" shipment, and must be in conditions apply: compliance with, inter alia, 49 CFR (a) Freight classification: 173.393 through 173.399. "C o n t ainer, radioactive c. The freight classif; cation is based on the materials shipping, empty." nature and identity of the " product" (b) DOT llM proper shipping being shipped; the freight rate name: " Radioactive materials, determined by the total weight of the small quantities." g product plus its packaging, and the (c) "EMITY" label: Yes route. The usual freight classification (d) " Radioactive" label: No for an " empty packaging" as described J in a., above, is " container, radioactive la materials shipping, empty," (UFC 9, (3) Uranium shielded casks: Casks Article 20)05). Note here the possible using uranium shielding are differences between classification under considered as " radioactive devices" freight tariffs and " proper shipping under 49 CFR 173.391(c) if the name" under the DOT regulations. It is external surface dose rate does not d possible for a shipment of an empty exceed 0.5 mrem /hr., and the U packaging to be classified under the content does not exceed 3 curies. If freight tariff as empty, but considered either of those limits is exceeded, under DOT regulations as a radioactive the proper shipping name for the materials shipment. Four examples are cask would be " radioactive cited for guidance: materials, LSA" under 49 CFR 392. If empty (see c(1), above), (1) Clean, empty casks. Casks which do the following conditions apply: not contain any radioactive (a) F r e i g h t classification: materials except for a " heel" or Container, r a d i o ac tive "r e si d u e," or

v. hose surfaces materials shipping, empty."

(internal and external) are " clean" (b) DOT IIM proper shipping name (i.e., no "significant removable (whether " clean" or containing radioactive contamination," as that residuals): term is used in 49 CFR 173.389[fj _l,, Not over 0.5 mrem /hr. or and 173.397), are not regulated by 3 e1: " R adioactive the DOT. The following conditions m a t e riais, smal1 apply: quantities." (a) Freight classification: 1 Over 0.5 or 3: " Con t ainer, radioactive " Ra dioa ctive materials, materials shipping, empty." LS A." (b) DOT IIM proper shipping (c) " EMPTY" label: Yes name: None (d) " Radioactive" label: Yes, if (c) " EMPTY" label: Yes shipped LTL (49 CFR (d) " Radioactive" label: No 173.392[aj); otherwise no (173.392 [bj ). 19 Approved: July 14,1975 l

ERDA Appendix 5201 Part IV TRANSPORTATION OF PROPERTY (e) Additional marking on cask: b. If fissile and not " Radioactive LSA." exempt: Yes .st if LSA and not (4) Uranium hexafluoride: UF, e xe mpt: Yes, if cylinders, when " empty," usually shipped LT L; contain " heels" of UFe, weighing c,therwise no. up to about 25 pounds (see DOT Special Permit 6273). Where the H. R ADI ATlON LEVELS-EXTERNAL contents do not exceed the SURFACES OF VEHICLES "e x e mpt" levels in 49 CFR 173.391(a), the cylinders may be The DOT llazardous Materials Regulations prescribe l considered under DOT regulations the maximum permitted radiation levels relative to l as empty, containing residuals, as in the external surface of the car or vehicle. (See 49 l 2, above. if the contents exceed CFR 173.393[jl.) Although this reguhtion is not i those levels, then the shipment specific as to how this provision is to be applied in must be considered rs a shipment the case of open top or flat bed cars, trailers, or of ra dioactive materials. The following conditions apply: trucks, its primary purpose is to protect persons who might be walking around or by a loaded vehicle. (a) F r e s g h t c la s sifica C ons: "Urcalum fluorides" (UFC 9, Therefore, in applying the regulation to open top or flat bed vehicles, the term " external surface of the car Article 92S74) (lower freight or vehicle" should be interpreted to mean either: rate than for empty 1. containers), For surface measurements: at any point on the outer surface of the vehicle, including (b) OOT IIM proper shipping the upper and lower surfaces, or,in the case name: of an open vehicle, at any point on the J., If exempt' " Radioactive vertical planes projected from the outer m a t e riais, smalI edges of the vehicle, on the upper surface of 2 If not e xempt: of the vehicle. ~/y quantities." the load, and on the lower extemal surface "Ra dioactive materials, 2. For measurements at 6 feet (2 meters): at LSA" (if n atural or any point 6 feet (2 meters) from the vertical depleted UFe); or " Fissile planes represented by the outer lateral radioactive materials" (if surfaces of the vehicle, or, if the load is enriched UF ). 1 " EMPTY" label: No transported in an open vehicle, at any point 6 6 feet (2 meters) from the vertical planes ,4_ " Radioactive" label: projected from the outer edges of the .a_ If exempt: No vehicle. ./ Approve:I. July 14,1975 20 d

\\ TRANSPORTATION OF PRCPERTY ERDA Appendix 5201 PARTV PACKAGING OPERATIONS A. STANDARDS the design has been reviewed by the Nuclear Regulatory Commission to determine that it (In preparation.) is in compliance with the package standards in 10 CFR 71, and an appropriate license B. PACKAGE DES 1GN APPROVAL amendment or Certificate of Compliance is PROCEDURES issued.

1. General. The Department of Transportation

4. Certificates of Compliance. Procedures to be,

ik (DOT) has transferred the administrative observed in issuing Certificates of re quirements for radioactive materials Compliance pursuant to 49 CFR J package approval from the DOT to both the 173.393a-396 are as follows: Energy Research and De velopment Administration (ERDA) and the Nuclear a. Safety Analysis Review Regulatory Commission (NRC). The DOT regulations require that either ERDA or (1) Preparation of Safety Analyses by NRC approve designs for packages (including Contractors. ERDA contractors total containment systems which may shall prepare a Safety Analysis involve the vehicle), other than specincation Report for Packaging (SARP) for packagings, which are used to ship any each package or packaging system , quantity of fissile material or more than a design. See 10.c., below, of this ' Type A quantity of other radioactive part for information on the SARP h material (with certain specified exceptions), content requirements. Obsolete Q NRC regulations (10 CFR Part 71) have packagings no longer in use and been amended to reflect NRC assumption of containers used for onsite responsibility for approving the package movement of materials are not design. Packages for the shipment of subject to these documentation complete nuclear we a pons, weapon requirements unless they are components, and nuclear explosives are reactiva:ed, altered, or requested excluded from the approval and certification for use in offsite shipments. In such requirements described in this part. Instances, the person requiring i reactivation and/or alterations shall

2. Purpose of Procedures. Evidence of package prepare or have prepared the

.ipproval for all ERDA field ofnees and appropriate SARP. license exempt ERDA contractors will be in the form of an ERDA Certificate of >(2) Review of Safety Analyses by C mpliance (Form ERDA-618)(see exhibit Co ntractors. ERDA contractors

1) issued in accordance with the procedures shall make an internal review of the listed in this appendix.These procedures (1)

SARP. This review must be identify the actions and documentation performed under a formal relative to applying for and issuing ERDA management review system within Certificates of Compliance; and (2) identify the contractor organization, and the officials who are responsible for must evaluate all assumptions and evaluations of package designs and issuing calculations made by the designers y, the Certificates. and users. The ERDA contractor may make use of outside

3. Use of ERDA Package Designs by Licensees.

consultants as necessary and Many packages d: signed by license exempt appropriate for this review. The five s ERDA contractors are adaptable for use ty primary categories of evaluation licensees. Package designs which are are: (a) structural integriT. (t) developed by license-exempt ERDA thermal resistance, (c) radiation contractors, and approved by a field office shielding, (d) nuclear criticality manager, may not be used by a licensee until safety, and (c) quality assurance. 21 Approved: July 14,1975 I l

a ERDA Appendix 5201 Part V TRANSPORTATION OF PROPERTY ~ l X J (3) Submittal of Safety Analyses to Duplicate computer runs are . ERDA. After completion of the not ' required, provided the internal evaluation, and corrections codes and assumptions are .of the SARP as necessary, ERDA reviewed for pertinence and contractors shall formally submit technical adequacy. the SARP to the appropriate ERDA (c) The field office manager will field office. In the transmittal, a determine when md if field statement must be included that o ffice evaluation personnel the procedures in this appendix should witness the regulatory have been followed, performance te sts (drop, -l p u n c t u re, fire, immersion) ] which are required by 10 CFR (4) Evaluation of Safety Analyses by 71. 1. FRDA (d) Field office managers shall- .~ assure that all inspections and (a) The field office manager shall procedures described in the arrange for a formal ERDA contractors' quality independent field office assurance program have been e valuation of each SARP carried out as described in the submitted by ERDA program outline. At his option, eontraetors under his' and if considered necessary, jurisdiction. The purpose of the field office manager may this evaluation is to serve as a arrange for concurrent or backup for the technical work independent inspections by donc _ by the contractor. All ERDA during fabrication of steps covered by the ERDA the packaging. At a minimum, i contractor in his SAP.i> eview the vendor records of quality. /;} should be evaluated and the assurance shall be reviewed. validity of results and (e) The field office manager shall conclusions ve n ned. An maintain a formal file to evaluation summary shall be document the extent of the prepared to describe the ERDA evaluation. The file evaluation and six copies shall must include the technical be forwarded to the Division of discipline (s) utilized in each EnvIronmenta1 Control evaluation category, the SARP, Techn ology, together with the ERDA contractor three copies of the SARP. submittal, and the ERDA (b) Whatever technical expertise is Certificate of Compliance, ne ce ssary to perform the (f) 'lhe field office managers shall evaluation in the live primary require the ERDA contractor categories shall be utilized, To to correct the SARP as the extent that outside necessary prior to submittingit expertise is needed for the for pub 1ication and . evaluation, the field office distribution, as provided for in manager. shall obtain such 10.b., below. expertise from other of his contractors, from other ERDA field, of fices or their b. Issuance and Distribution of contractors, from elsewhere in Certificates 'the ERDA, or from outside - consultants. 'In.no case may (1) Field office managers: pe rson n el.who have (a) issue a Certificate of participated in the preparation Compliance as outlined in or internal review of the SARP ection S., below, i . by the ERDA contractor be (b) forward six copies of the l!., used in the ERDA evaluation. Certificate of Compliance , Approved: July'.14,1975 ' 22 a.

-^ ^ ^ ~ ERDA Ap' pendix 5201

0' i

' TRANSPORTATION OF PROPERTY Part V to the Director, Division ~ noted below, a' four digit number to of Environmental Control! -be : assigned from the following Technology, blocks of numbers: (c) maintain a file of names. and addresses of users of AL: 9501 9560 each Certificate issued by CH: 9561 9595 each field office, and send GJ: 9596-9600 - copies of any' revisions of a HQ: 9601 9760 Certificate to each user of ID: ' 9761 9780 that-Certif'cate. (See NR: 9781 9840-5.c., below.) NV: 9841 9850 (2) Direetor. Division of OR: 9851 9900 E n vli o n m e n t al Control RL: 9901 9930 Technology: SAN: 99319960 (a) prescribes procedures and SR: 9961 9999 forms to be used by the field offices in processing Note 1: Where. a DOT. Special C e r t i fIc a t e s of Permit formerly applied to a Compliance, package,. the same specific (b) assists the field offices, as . iden tliication number will be requested,in arranging for carried over into the new review. and evaluation of identification mark, e.g., DOT SP any portions of the SARP 4567 would become USA /4567/. which were not evaluated By agreement with the Nuclear by the field office. Regulatory Commission. (NfS) (c) meintains a central file of . where a licensee is authorized by the 6 Certificates of Compliance NRC to use an ERDA field office issued by the field offices approyed package, the and the. Nuc1 ear identification number would be the Regulatory - Commission, same as assigned by the field office, (d) sends copies of each and vice versa. Certificate to the DOT (Office of flazardous Note 2: Certificate revisions must hterials) and the Nuclear be identified in block 1-b of Form Re gulatory Commission. ERDA 618. Revisions and revision j (e) prepares and isse - a numbers may be issued only by the monthly sumr y af field office mar.ager issuing the Certificates issued by both original certificate. In the special the field offices and the case of the family of UFe Nuc1 ear Regutatory packagings under former DOT Commission. SP4909, the revision number would follow the family mark, e.g.,

5. Contents of Certificates of Compliance, revision 3 would be indicated as Each Certificate, of Compliance shall be on 49095 3, 4909 8 3, 4909 12 3,-

i Form ERDA 618 (exhibit 1) and shall 4909 30A 3 etc. { contain at least the following information: Note 3: The Nuclear Regulatory a. Certificate. of Compliance Number Commission is assigned the block of (block la). This mark includes a prefix, numbers 9001-9500. ) a unique and specific identification j number, a type code, and a suffix (3) Type Code: A single or multiletter according to the following: designation of the type or proposed , (1). Prefix: The letters " USA'." ' A -Type A package design. '(2) Identification Number: Except as B - Type B package design. 1 23: Approved:. July.'14,1975 . l;

1 l 1 ERDA Appendix 5201 Part V TRANSPORTATION OF PROPERTY ) BL - Large radioactive quantity This shall include materials of package design. construction, gross weight, general F - Fissile materials package external and internal dimensions, design. appearance, method of closing, and model number. (4) Suffix: "(ERDA * *)" (asterisks to be replaced by the two-or g. Brief Description of Authorized three letter identification code Contents (block 5). This shall include assigned to each office). The suffix the physical and chemical forms, the must he in brackets or parentheses, approximate quantities (including radionuclides, if appropriate) in cunes, amounts in grams (for Ossile materials), (5) Examples: Oak Ridge's UF whether special form, the corresponding 6 protectiye package. transport index numbers (for Fissile US A/4909 12/B F (ERDA-OR) Albuquerque's Model LLD-1 Fissile Class 11 packages), allowable numbers of packages on vehicles (for Fissile Class 111 Package Birdcage: USA /4960/BF (E RDA-AL). packages), expected heat removal capacity (in BTU /hr), and any restrictions on the contents which might b. Certificate Revision Number (block Ib). not be obvious from the nature of the See Note 2 to a.,above, packaging. Additional pages may be added for additionally authorized Package Identification Marking (block contents. c. Ic). This is the symbol that is marked i on the packaging, and in the shipping h. Reference to Operating Instructions papers, in accordance with the DOT (block 5). This shall include a reference regulations [49 CFR 173.393a(a)(2) to: and (aX3)]. It is the same as the (1) a n id e n tifia ble document Certificate of Compliance numberin containing instructions on the use block la, except that it would also and maintenance of the packaging. contain the revision number in cases (2) any special actions to be taken by where the revision involved a design the shipper prior to the shipment. change to the packaging requiring some structural or geometrical change.

i. Restrictions (block 5). This shall include Packagings would not need to be any areas in which the p.ickage design is remarked for certificate revisions not fully in compliance with the ERDA involving changes in authorized regulations, and any restrictions on the contents, expiration dates, reference use of the package with regard to modes documents, or other changes not of transport, types of vehicles, freight involving packaging design changes.The containers, or supplementary new marking on the packaging would operational requirements. (Note: such then indicate that (Fe necessary restrictions will probably require the structural changes had been made, issuance of a DOT special permit for an exemption from some part of the DOT d.

Page Number (blocks Id and le). The regulations.) cover (signature) page is always page 1. The total number of pages in the

j. Other References certificate is noted in block le. All pages must be numbered, dated, and k.

Dates (block 6). The date ofissue and, identified by the Certificate of if appropriate, an expiration date. Compliance number. 1. Approval Signature (block 7) e. SARP identification (block 3)

m. Append!ces. Alterna tive package f.

Brief Descriptiu of Packaging or contents, other necessary technicaldata Vehicle Containment System (block 5) or information, and modifications and Approved: July 14,1975 24

SRDA Appendix 5201 TRANSPORTATION OF PROPERTY Part V arnendments may be included in (c) prior to the first use of.the appendices. package, register in writing as provided for in 6.c., above.

6. Use of Certificates of Compliance (3) Packaging designs previously approved under the " grandfather" a.

Previously Approved Packages clause of chapter 0529-056 may - not be used for shipments of (1) Package designs which have been radioactive materials until a SARP evaluated and approved by either has been prepared and evaluated as the Nuclear Regulatory described above,and a new ERDA Commission (in accordance with Certificate of Compliance issued. the provisions of 10 CFR Part 7.1) or by an ERDA field of0ce (in (4) For those package designs which accordance with the requirements have been previously approved by a of this appendix), or which have field office manager, but which { been p u blished in the DOT have not been subject to the type regulations as "spe cification of analyses and evaluation described containers," need not be further in t hs appendix, field office evaluated by any other ERDA managers shall assure that steps are office whose contractors wish to taken to prepare and evaluate a use the approved packaging. In SARP in accordance with the these cases, however, the ERDA procedures of this appendix.Where field of0ce whose contractor is evaluation procedures have already using the packaging must assure been carried out, the field office that all limitations on loading and manager shall assure that the entire D usage conditions imposed by the process has been adequately approving ERDA field office are documented, includin;; preparation followed. Should any changes be of a formal SARP if one does not necessary in such limitations or already exist. conditions, these changes must be formally analyzed and evaluated in accordance with the procedures in b. Foreign Packages this appendix A report of this evaluation must be forwarded to the original issuing field office for (1) For packages having an IAEA. type modification of the ERDA approval of a foreign competent Certificate of Compliance (see 5., authority, no further ERDA above). approval is needed for either export (2) Each ERDA contractor using a or import shipments, provided that j previously approved package shall: the package meets the pertinent 1 (a) have a copy of and comply requirements of the IAEA with the specific approval regulations, and the foreign ' document (NRC license or competent authority certificate has ERDA or NRC Certificate of been revalidated by the Department Compliance) for the p.ickage; of Transportation (Office of and all documents referenced llazardous hlaterials), and provided in the approval document further that the license. exempt (such as operating instructions) ERDA contractor using the package relative to the use and for export and import shipments: maintenance of the packaging, and the ?ctions to be taken (a) has a copy of and complies prior to shipment, with the foreign competent (b) comply with the applicable authority certificate; the DOT D DOT and NRC regulations and revalidation; and all documents ERDAM's 0529 and 5201. re fe renced in the foreign 25 Approved: July 14,1975

ERDA Appendix 5201 Part V TRANSPORTATION OF PROPERTY certificate relative to the use packages); the DOT Special ?ermit x and main te n ance of the number (if any); and the model packaging, and the actions to number of the packaging. Tha be taken prior to shipment, registration must be sent to one of (b) complies with the applicable the following: 1AEA, DOT,, and N.RC regulations, and ERDAM's (a) Fo r licensed packages: 0524 and 5201. Assistant Director for Feel (2) Foreig, designed and approved Cycle, Nuclear Regulatory packagings may not be used for Commission. d o mes tic transportation of r a dio a c t ive m a t e ria ls,-i.e., (b) For field office approved shipments which originate at a packages: the field ofilce point in the United States and are issuing the ERDA Certificate destined to another point within of Compliance. the United S t a t e s-unless a Certificate of Compliance orlicense (3) When a field office issues a amendment has been issued by a Certificate for a package which was field office manager or the Nuclear previously authorized under a DOT Regulatory Commission, as Special Permit, the issuing field described above. The field office office shall contact DOT (Office of manager may base his approval llazardous Materials) to obtain a either on tacit acceptance of the list of previously registered users, foreign approval, or on independent and shall send a copy of the review. Certificates of Competent Certificate to each such user. Authority issued by Great Britain, Canada, Federal Republic of

7. Existing DOT Special Permhs. Packages-Germany, Italy, and France may meeting the regulations may be covered by a generally be relied upon to indicate special permit already issued by the DOT.

s a scope and degree of review Those special permits will remain in effect paralle! to that of the United until they reach their stated expiration States, and would not normally dates. Beyond that time, package designs require an independent ERDA must be covered by an ERDA Certificate of review. Compliance. Packages already covered by a DOT special permit are authorized for c, Registration of Additional Users continued use under the conditions stated in the DOT special permits beyond the permit (1) Each user of a package approved expiration date(s) provided the user has unde; a Certificate of Compliance requested an ERDA Certificate of must register his name and address Compliance prior to the expiration date. An with the Geld office issuing that Interim Certificate of Compliance will be Certificate. This will allow each issued by the field office. The interim field office to notify each user of Certificate will remain in effect until the any changes in the terms of the corresponding SARP has been finally Certificate. Any changes to the approved or rejected by the ERDA. Certificate muu therefore be made only by tb original issuing field

8. Certificate Revisions of0cc.

(2) Each registration must include: the-a. All revisions and changes to a Certincate name and address of the additional of Compliance shall be issued only by user; the name and license number the field office originally issuing the of the holder of the applicable 10 Certificate. Other field offices desiring a CFR Part 71 license (for licensed change si all conta;t the original field packages) or the ERDA Certificate office, providing such backup and of Compliance iden tification 3 support as is needed to comply with the J' number (for Geld office approved SARP requirements. Approved: July 14,' 1975 26

ERDA Appendix 5201 TRANSPORTATION 0F PROPERTY Part V b. Minor revisions may be issued on Form evaluation of the package ERDA.618 as an addendum. The design. Certincate need not be completely rewritten each time, but when two such (2) Director, Division of Environmental addenda have been. issued, the next Control Technology (ECT) shall; change should be made as a complete revision. Each revision requires a new (a) assign a priority for Nuclear cover page and signature. Re gula t ory Commission review, based on the

9. Nuclear Regulatory Commission Review of.

recommendations of the Geld License. Exempt ERDA Contractor Package o f fIc e manager, and Designs considering the priorities of other concurrently requested a. This section sets forth the reviews. administrative procedures for Nuclear (b) transmit the material to the Regulatory Commission review of Nuc1 ear Re guIa t ory license exempt ERDA contractors' Commission, package designs. These procedures are 6:) Advise the cognizant Geld consistent with the " Agreement office of the results of the Between the General Manager and the Nuc1 ear Re guIa t o ry Director of Regulation for Package Commission's review. Design Reviews"(annex C). b. All package designs developed by (3) The Nuclear Regulatory license-exempt ERDA contractors to be Commission, pursuant to agreement used for shipments of Type B, large (see Annex C), will: quantity, and fissile radioactive (a) schedule the package c'esign D materials, must be submitted to the review and advise ECT of its Nuclear Regulatory Commission for schedule. r e view. These procedures do not (b) review the material furnished preclude immediate or continued ERDA and determine whether the use of Reid office certified designs to package design meets the meet contractor programmatic requirements of 10 CFR 71, requirements in scheduling its review of and make direct contact with package designs, the Nuclear Regulatory field of0ce staff to resolve Commission staff will consider the technical matters. priority assignment established by the (c) issue a memorandum to ECT ERDA field offices. setting forth the results of the c. The following procedures apply to review. obtaining the. Nuclear Regulatory d. The p'riority me frame which is Commission review: assigned to a package design for its review should be based on known or (1) Field Office Managers shall transmit expected usage of the package by to the Division of Environmental licensees and other license-exempt Control Technology for processing: contractors. The following order of ) (a) three copies of the Safety uriority is suggested, but is not Analysis Report for Packaging inandatory: (S A RP), prepared and (1) Known or expected use by a' processed in accordance with licensee to return materials to the ERDAM 5201. license exempt contractors. (It (b) the related interim Certincate should be noted that Nuclear 'j o1 Compliancc Form Regulatory Commission review E R D A-618 and any does not replace the requirement amendments thereto. for obtaining a license. Such review, (c) A recommended priority to be h owever, should facilitate and D assigned to the Nuclear minimize the time required for such Regulatory Co mmission's action.) i. l l 27 Approved: July 14,1975 l

a ERDA Appendix 5201 PartV TRANSPORTATION OF PROPERTY (2) Use by a licensee which is unrelated Federal regulations in 49 CFR 173.22 hold to the contractor's operations. shippers responsible for assuring that (3) Wide usage by license exempt shipments of radioactive materials and other contractors. hazardous goods are rnade in authorized (4) large volume use by a single packages. Exceptions are authorized on a contractor. case-by case basis by the DOTin the form of Note: New package designs should take a Special Permit issued by the llazardous pr e fe rence over existing package Ma terials Regulations Board. DOT's designs. procedures for applying for and processing Special Permits are published in 49 CFR

10. Guide for Preparing Safety Analysis Reports 170, and in ANSI Standard N 14.10.1. Oy for Packaging (SARP) using specification containers, shipments may be made without the need for safety a.

N eed for Documentation. Package reviews by NRC, ERDA, or DOT, or a designs that have been certified by Special Permit. In addition, there is a either a field office or the Nuclear potential cost savings in that a special design Regulatory Commission as meeting effort is not necessary. Moreover, container regulations and package designs for manufacturers may, in some instances, be which specincations have been issued by able to provide shippers "off-the shelf" the DOT may be used by an ERDA Deld delivery thereby eliminating the time of0ce or contractor for its own required for cuMom fabrication of shipments. Therefore, it is essential that containers. When and to the evtent that U.S. technical in formation and limits container specifications are included in the pertinent to the construction and use of International Atomic Energy Agency these packagings ba available to all (1 AE A) rules, international shipments will be potential users. facilitated. Such a step would promote easy exchange of U.S. containers in foreign b. Form of SARP. The SARP must be a commerce. bound distributable document, and must be prepared and, if unclassined, 2. Processing of Specification Container submitted to the Technicalinformation Proposals. When a requirement for a Center in accordance with appendix container specification is identified, a draft 3201, part til, B.2., for reproduction proposal must be coordinated with the and distribution based upon need. Division of Environmental Control Technology to avoid duplication of effort. c. Contents of SARP. The SARP must There should be assurance at the field of0ce contain at least the information level that the necessary development and specined in Sections 71.2171.24 of 10 test work is performed in connection with CFR Part 71, and also the quality the particular design and that a container assurance program information referred specification proposal in accordance with to in ERDA appendix 0529 as well as DOT format is prepared. It should be this appendir.. See annex D for details written as broadly as possible, but within the on SARP preparation, scope of the test resalts and evaluailon made for the particular container design, it should C. PROC ESSING OF DOT SPECIFICATION CONTAINER DESIGNS also provide for construction of packagings of varying sizes, configurations, and loading 1. Specifkation Containers. To assure a broad capacities to facilitate the use of the package for other materials. Formal specification, spectrum of DOT packagine specifications container proposals, along with a Safety and to encourage package standardization, Analysis Report for Packaging, must then be container requirements need to be reviewed submitted to the Director, Division of on a continuing basis by the field to identify Environmental Control Technology, for areas where new container specifications coordination of Headquarters and other field need to be developed. office review. Approved: July 14,1975 28

ERDA Appendix 5201 TRANSPORTATION OF PROPERTY Part V O. Q U A LITY ASSURANCE FOR PACKAGE examinations, and tests; calibration of FABRICATION, MAINTENANCE, AND USE instruments and equipment; and control of nonconforming items. In accordance with ERDAM 0529, a documented quality assurance program for-radioactive and fissile 6. Certification of personnel and equ!pment material shipping containers must be established by efforts include required training, testing, and ERDA contractors. The same basic requirement certification of manu facturing and applies to packages ' for all types of hazardous inspection personnel involved in special materials. The objective of such quality assurance processes, such as welding and programs is to assure that hazardous material shipping nondestructive examination, and the containers are fabricated, maintained, and used in required certification of equipment and compliance with established safety and engineering procedures used in the performance of standrds. To achieve this objective, controls are special processes. Problems have been noted ne ded, as a minimum,in the following areas: in the past where packagings suffered from inleakage of moisture and corrosion. Water 1. Management and planning efforts involve can cause loss of strength, moderation formulation, direction, and documentation changes, and weight excesses. Resultant rust of the entire quality assurance program; and oxidation can also cause material designation of organizational, (including failures and sealing problems. vendor, fabricator, and user) responsibilities for quality assurance; preparation of quality 7. Operation, maintenance, and modification assurance program plans, procedures, and efforts laclude quality assurance through instructions; training and indoctrin4 tion of systematic planning of work; application of personnel; conduct of periodic, documented work instructions or operating procedures program audits, and independent inspections for controlling operation, maintenance, and and reviesys; maintenance of records; and modification; preparation of records and 9 preparation of quality status reports. reports of operation experience; and performance of sched uled, periodic 2. Design and development efforts in the inspection and retesting, including routine qualit y assurance program include instrument calibrations, to assure that e s t ablishing, controlling, and verifying reusable containers continue to meet the design, using designated applicable codes and applicable design standards. standards. The development effort encompasses p1anning, testiug, 8. Records requirements to provide that documentation, surveillance, and closed loop quality assurance records are maintained in review, re po r ting, and feedback of an auditable file during the service life of the development information, containers. 3, Acceptance criteria in terms of measurable 9. Reference Standards. ERDA and NRC safety characteristics, and the effects of standards for the packaging of radioactive appropriate regulatory tests. and fissile material shipping containers are contained in ERDAM 0529 and in 10 CFR 4. Procurement efforts include the Part 71. Engineering standards are set forth 1 specification of quality a ssu ra nce in IAEA, ERDA, NRC, DOD, ASME, and requirements in procurement documents, ANSI dNuments. For guidance in selection and surveillance of suppliers, and developing a comp rehensive quality preparation for delivery and inspection of assurance program, see RDT F.2 2T, June purchased items. 1969, " Quality Assurance Program Requirements," and Appendix 13,10 CFR 5. Fabrication efforts include establishment of Part 50, manufacturing plans consistent with the quality levels, conformance to drawings, E. DIRECTORY OF P ACK AGINGS FOR standards, specifications, procedures, and T R ANSPO RT ATION OF RADIOACTIVE instructions for the control of materials, NIATE RIALS D components, and processes; performance of in process and final assembly inspections. 1. Scope. In promoting maximum utilization af 29 Approved: July 14,1975 l

ERDA Appendix 5201 1 Part V 1 TRANSPORTATION OF PROPERTY shipping co ntainers, the ERDA has managers of field offices shall submit to the published a directory (WASil 1279) of Director, Division of Environmental Control reusable radioactive material packagings. In Technology, the basic data indicated be',ow, developing a directory of such packagings, The data shall be submitted in final photo principal consideration was given to packagings that are costly to fabricate or, copy form (typed on 8" x 11" white paper), ready for transmittal to the printer. An because of design factors, would be difficult isometric or cutaway sketch for use in the to purchase on short notice. In general, packagings having a fabrication cost ofless directory must also be included. than $50 in small lots were excluded from DATA SHEETS consideration, unless the design had unique features that may not be common 1.ERDA Ce rtificate of Compliance knowledge among other potential shippers. Number:

2. Common Name or Model Number:

Expected benefits of the directory include:

3. Date of Most Recent ERDA Certificate (a) its use as a tool in promoting Revision:

standardization in packaging design and

4. Description of Packagirig:

increased utiliza:lon of existing packagings,

5. Int erio r and Exterior Cavity (b) identifying packagings which have b~n Dimensions:

tested and evaluated according to recei.ay

6. Type and Thickness of Shielding:

adopted performance standards; and (c)

7. Authorized Contents:

providing current in forma tio n for

8. Ileat Removal Capacity:

radioactive material packages being shipped.

9. Special Conditions of Use:

10. Number of Packagirgs Owned:

2. Publication of Packaging Directory. The 11, Identification and Data of Safety Division of E n viro nmen tal Control Analysis Report: Technology shall develop, maintain, and

12. IAEA Certified: YES f!O -

publish a directory of representative

13. Other Pertinent Data:

packagings based on inventory data to be

14. For Additional Information,

Contact:

submitted by the field offices. This directory will be made available as a reference source F. A PP LIC ATION FOR IAEA COMPETENT to packaging designers, shippers, carriers, transportation regulatory agencies, and other AUTHORITY CERTIFICATES interested parties. (in Preparation.) 4 3. Data R equirements. For each newly G. TEST PROGRAMS designed packaging or significant change to a previously approved packaging design, (in Preparation.) 1: ,f. f Approved:.luly 14,1975 30

,a TRANSP01(TATION 0F PROPERTY ERDA Appendix 5201 ANNEX A % M %%%%%h Participation in proceedings related to Title 49 U.S C., section 22. as amended carrier applications to regulatory bodies by Public 1Aw 85-346, provides that rate Ag PR0P Y ggy for temporary or permanent authortty tenders to the Oovernment must be filed to operate in spec!!)ed geographical loca-by the carriers with the interstate Com-tions shall be confined to statements or merce Commlaston except for "any quo. Chapter 109-Atomic Energy testimony in support of a need for service tation of tender which, as indicated by Commission and shall not extend to support of indi-the U.S. Government, or any agency or SuscMarfst 0 -TsANSPOItan0M ANo Vidual carriers or groups of carriers. Department thereof, to any carrier or carriers involves information the dis. Motos vowittil $ 10940.106 Re ports. closure of which would endanger the PART 109-40--TR AN5P0tTAfl0N Reports which are specifically re* national security." Carriers will be in. AND TRAFFIC MANAGEMENT quested by OGA or are prescribed in Fed-formed by the negot'eiting ometal if any eral Property Management Regulation quotation or tender to the U.S. Atomic his part is being lasued to set forth 10140 shall be submitted e the Division Energy Commisalon involves such infor-AEC implementation and supplementa-f Waste Management and Transportation mation. tion of rederal Property Management five days prior to the established due date $ 10940.307 Tonnage repo-ts. Regulattoris. Part 101-44-Transporta, so as to permit timely transmittal to GSA, tion and Trame Management' The format to be used by Deld officas for Tonnage reports required by y'PMR ice ao o00 scope of part reporting as indicated above shall be as 10140.307 shall be submitted to the Divi-see 100-40 oco4o Appiseability to contractore prescribed in the specine requests or ap. slon of Waste Management and Transpor-Nepr*e's'en' tat on Propriate section of the FPMR. tation 6 woriting days before the end of efore regu, each calendar month so as to allow for t too 4o103 r,r bomes $ 10940.109 l'tilisstlen of special coa. timely transmittal to GSA. Tonnage re. '8""*""** presenting commodities under AEC ne. 300-40 :09 Uuitsauon or spectat con. $otiated rates authorized by AECPMR tracta and agreementa Prom time to time special transporta-09-40.305-3 shall not be reported to los-40 3 rretant run. routu. and tion agreements are entered into on sermees-a Government. wide or an AEC wide

USA, baats and are applicable generally to AEC $ 10440.50 llilla of lading.

so tau nY; er agencies shipments.The Division of Waste Manage i os stegrts or agency ment will disttwute lnformation on such 6 109 4 0.5000 Scope of subpart. nesous-tos-40 aco a agreements to Geld of0ces as it becomes This subpart sets forth the require-100 40 306-6o Mesoussions lavolvtas ns. tional security svallable, ments under which r ommeretal or Gov. j 100-40 301 Tonnase reporta. $ 10940.3 Freishe rates, routes, and ernment bills o' lading or express re-l D 109-406ool N N' todo sub st. Potter. I 109 4 0.301-3 Cost comelderation. $ 10%40.5001 Polley. NN coNrNi bute of tadtag or Premium transportation shall be timed Generally AEC cost. type contractors commeretal empens receira only where the additional cost is clearly will W commercial bills of lading or nos.40 6004 Oovernment bma of ladir.s justified. When premium transportation commcretal express receipta 1.. making too-40 s t Price. A nderson coverage la used gor ahlpments in eIcess of 600 shipments for the account of the AEC. ceruncatione pounds. a written statement supporting Coat-type contractors may be authorizew 109 40 $100 Scope of subpart* the use of such transportation shall be by the contracting omcer to use Govern. 109-40 Ston Policy. retained in an appropriate file. ment buls of ladmg if such use wt!! be i10940.305 3 Negotiation by othe, abanWm 2 h NmM o iN p riu$t see 1st tem 1 f.pergy Act or 1944. as amended as Stat. 04a. agmite. I 109 4 0.5002 Applicabuity. 42 U s c. 2201 see 20s. rederal Property saa The limitations in FPMit 101-40.305-ne polley and proceditres set forth in 80 "40 0 c 4ss'4 3(a) do not apply to the initiation and this subpart shall be applied when AEC's conduct of negotiations for freight rates cost-type contractors use commerstal a sa sta 4 109 4 0.000 Scope of part. and services related to ab1pments of bills of ladmg or commercial express nuclear weapons and radioactive and receipta. This part prescribes AEC regulations flasue mateMals. I10%%0.5003 Cornmmlal bille sJ lad. governing transportation ar.d trame manasement activit'es, which regula. $ 10940.305-5 Iteports of asency ne-ing or comenmaal espress receipts. Lions implement and suppiement Federal gotiations. M's cost type contractors ualns Property Mautement Regulations. Subject to the provtalons of FPMR commercial bills of ladin2 in making i 10940.00N50 Applicabluty to con. 101-40.305-6 a complete report of each shipments for the account of the Atomic negotlation fother than those related to Energy Commission shall include the trar ters. nuclear weapons. radioactive and fisade fs11owing statement or one substantially FPMR Part 101-40. Transportation material ihlpments, and all other com* the same on all commercial bt'is of and hame Management. and AECPMit modttles when the quantity involved is lading: 10040. Transportation and Trame Man. less than 100 short tons of a single com* Thta ahlpment la for the account of the agement. should be appimi to cost type modity or mixed commodities to be tLs. oovernment which wui assume the contractors' transportation and trade moved by common carrier from the same freight charges and ta subject to the terma management activities Departure by consignor to the same consignee within and conditions set forth in the atindar i form cost type cont. actors from the provisiona a 30-day periodi shall be submitted to of the U s covernment bttle or lading nd of these reguls tons may be authorized the Dividon of Waste M.inagement and to any avattable spectal ratn or chargn. Transpwtation promptly after each nego. (b) ne foregoing language may he p actices arfd d es olowe are Listlon is completed for transmittal to varied without materially changing its conststent with the basic policy ob}ectives GSA. Esch report shall be in memorandum substar:ce to satisfy th I eeds of particu. in these regulatform and except to the form referencing FPMR 101-40.305-5 lar coat type contractors for the purpose extent such departure is prohibited by and shait contain the data prescribed in of obtaining the benefit of the lowest statute or executive order. the FPMit's. Classified information shall available rates for the account of the not be included in the reports. Government. l10940.1 Ceneret providens. (c) Where practicable. commercial l 109 4 0.102 llepresentetion befe.e g 109 40.305. 50 Negotiations involv- ' "* af lading or express receipts may regulatory bodies-ing national sceurity. 'or consignment of a ahlpment D 5 31 Approved: July 14,1975

e e ERDA Appendix 5201 Annex A TRANSPORTATION OF PROPERTY } to the U,8. Atomic Energy Commlaston order copy (8F 1104) shall be annotated $ 10940.3101 Policy. c/o the cost-typt contractor or may Indl. with a typewritten, rubber stamp, or cate cor.stanment by the contractor for similar impression containing the follow

• Upon request of a carrier, an appropri.

the UE. Atomic Energy Commission.". ing woreting: sta ce.dfication will be tasued by an authorized representattve of the Atomic (di Commeretal bills of ladtng ex g,,gg zu,to, van, o,,,,,ywrrt Energy Commission to the carrier re. ceeding $10.000 lasued by cost-type con. Condtuon 9 hereof is revised as foHoare. garding the appl!cability of Price - tractors shall be annotated with a type

• The nondisertmanation clauses contained in Written, rubber stamp, or sin.llar impres*

Anderson Indemnity to a particular ah'p. slon containing the following wording: secuon 202 of gaecuuve order 11246 relauwe ment. to equal employment opportunity for all Egeefwe date. This part will bmome E.9UAL gMPt,oT MsNT OreostentrT persons witho at to t im en in's' affective 60 days af ter publication 1:Lthe The nondisertmination clauses conta in s.ction 202 of Enseuuve oraer utte.nned rulee and regulations prescribed by the PsonaAL i.gGIdf ra. tive to equa. employment opportunity for all seer,tary of tabor. are incorporated hereui. els. Dated at Germantown. Md. this 13th persons without ressed to raec, creed. color. (b) In those instances when AEC cost. day of February 1968. or nauonal orn ia. and the implementing type contractors are authorized to use s rulee s'id regulations of the Freetdent's Com. Government bills of lading, specific em. For the U.S. Atomic Energy Com-mattee on Equal E.tspinyment opportunity playess of cost-type contractors will be mission. ohtch. to the essent not inconsistent with Esseuuve f% der 11246. romana in full force authorized by the contracting omcer to J. A. EaLaws. tasue such Government bt11s of lading. Asstafant General #onom and effect se those of the secretary o* 1. abor. (See Title V. U.S. Government Account. M @#0"#- are :ncorporated berein. ing Osco Polley and Procedures Manual 8 FJt. Doc. es-sets: rued. Mar. 4 1948; j 10940.5004 Government bills of lad, for Guidance of Federal Agencies.) 8:4e a.m.l $ 109,40.5,1,;, Price. Anderson tal Before any Government bill o., eeverste ,,g;gg,,,, lading shich has not been revised to includ ' teference to Executive Order l 10940.5100 Scope of subpset. 10925. La amended. L. Executive Order This subpart sets forth the polley for 11246 h issued for use by AEC or cost. Issuance of certifications regard'ng type co ntractors (where authortzed) at Price-Anderson coverage of particular least th r ortginal (SP 1103) and ahlpping shipments. ) i I Approved: July 14,1975 32 j .s

TRANSPORTATION OF PROPERTY ERDA Appendix 5201 ANNEX B ACTIONS UNDER NATIONAL EMERGENCY CONDITIONS The emergency procedures described in this annex responsibility to develop plans and programs related have application to the ERDA and its cost-type. to the use of operation of surface transportation cont ractors' freight transportation activities. The media and the inland waterway carriers. procedures are predicated on pertinent Presidential Executive Orders which assign emergency 3. ALL0 CATION CONTROL 0F preparedness responsibilities and on published plans TR ANSPORTATION CAPABILITY of Federal agencies having transportation re s po nsibilities, including Interstate Commerce a. Allecation means the distribution by Commission Transport Mobilization Orders, appropriate authority of available transportation capability in instances when National and Regional Emergency Preparedness Plans, there is a shortage of such capability. Programs, and Procedures The allocation ianction for surface and air 1. GENERAL SERVICES ADMINIST RAT 60N transportation has been delegated by the (GSA) OFFICE OF PREPAREDNESS (OP) Secretary of Transportation to the Office of E m e rgency Transportation (OET). The GSA OP advises and assists the President in Allocation at a regional level may be determining r.ational preparedness prograrr. - policy necessary at such times as national controlis and assists m coordinating performance in this area. not or cannot be exercised. ERDA requests GSA O" has established regional offices to administer for allocation

• will be presented by the its program. ERDA appendix 0601 pro idts that an ERDA representative in each regional office ERDA representative assigned to each ot 'he reg:onal (See annex D to appendix 0601.) The t

offices will assure that in the event of a national Emergency Preparedness Coordinator of the emergency declared by the President, ERDA claims Department of Transportation will act for for resources, including transportation, are given the Director of OET until such time as an appropriate attention. See Executive Order 11051, OET regional organization is established. " Prescribed Responsibihtles of the OEP m the Allocations of transportation capability will Executive Offices of President." be in accordance with and will not supplant the controls applicable under ICC General 2. ASSIGNMENT OF SMERGENCY Orders lCC TM 2,3,4, and il. PREPAREDNESS FUNCT!ONS b. There are two types of allocations which Executive Orders assigning emergency preparedness may be provided during a national functions to Federal departments and agencies have emergency. They are: been issued by the President, and plans and programs have been and are being developed by these agencies. (1) Transport. allocations which are The Department of Transportation and the Interstate allotments of equipment or facilities for Commerce Commission have been assigned major the full time use and control of a user responsibilities affecting commercial freight for designated periods of time. This transportation activities. See Executive Order 11490 type of allo aion will be provided when t Assigning Emergency Preparedness Functions to the paity makMg a request can justify Federal Departments and Agencies (Part that there is n overriding, compelling l 13-Denartment of Transportation, Part need for full time use of transportation 21-interstate Commerce Commission), equipment or facilities. The Department of Transportation will develop and (2) Traffic allocations which are used to coordinate policies, plans, and procedures for designate the availability of centralized control of all_ modes of transportation, transportation service capacity which and determine the appropriate apportionment and still retains its common carrier nature. lh allocation of the civil transportation capability. The basis for a traffic allocation will be W m terms of quantity of freight (tons) to l~- The Interstate Comm e rce Commission has be transported between specified time 33 Approved: July 14,1975

~~ ~ ERDA Appendix 5:01 - Annex B ' TRANSPORTATION OF PROPERTY. periods. There are varying ' degrees of designated as General Permit Agent with traffic allocations as follows: authority to issue or withhold pennits and to designate permit agents. This (a) Informal allocation. Notice that the Order. contains a list of shipment total submittedirequirements for priorities, the highest of which includes transport' tion service can be met. ERDA shipments. a (2) ICC TM 3 " Motor Freight Embargo" i' (b) Formal restrictions. Notice that provides for co n t rols over the g part of the submitted requirements movement of traffic by motor carriers a cannot ' be met. The limitation . for compensation. Shipments will not 9: specified thca becomes a restriction - be accepted by carriers empt those against the total requested moving under (a) a bill of lading, (b) allocations, shipping order, or (c) permit, issued by the Energy Research and Development (c) Formal allocation. Notice that only ' Ad minist ration and certain '. other i stated tonnage of freight is' designated agencies. 1 authorized for movement from, to, (3) ICC TM 4 " Inland Waterways Freight or between stated areas. Embargo" pro.vides for controls and i shipment as indicated in connection with ICC TM 3,above. 4. ICC CONTROL OF SURFACE (4) ICC TM 11 " Control of Freight TRANSPORTATION Shipments to or Within Ports of Storage Areas" also authorizes a permit system + a. General. General Orders have been issued by of control. The ICC is named as the '4 Ihe ' ICC covering the emergency General Permit Agent with authority to mobilization of the commercial - designate other permit agents, t ranspor tation industry under its bi jurisdiction. Of these General Orders, which are "self. triggering," ICC TM 2,3,4, and 11, 5. CONTROL OF DOMESTIC COMMERCIAL AIR which have been distributed to field offices, TRANSPORTATION . t provide for controls on the acceptance of freight for transportation by carriers. In The Civil Aeronautics Board's War Air Service j addition, General Order ICC TM S provides Priority (WASP) Alr Priorities Manual previously 11 guidance for' disposing of undeliverable furnished to field ofGees and the Division of shipments resulting from disruption of Administrative Services in lleadquarters gives ERDA service due to enemy attack on the authority to administer the WASP Air Pilorities continental United States. System for the domestic movement of ERDA end ERDA. sponsored cargo through ERDA WASP Air b. Control of Freight. General Orders ICC TM Priorities Offices including authority to assign Classes 2, 3, and 4 provide that use of surface 2,3, and 4 priorities as defined in the Manual to such transportation into or within areas which cargo traffic. have been or are being attacked is embargoed. Rail transportation of essential Managers of field offices and the Director, Division of goods will be allowed under ICC TM 2, but Administrative S e rvices, on behalf of the only by special permit. ICC TM 11 also I-leadquarters division and office directors, are provides for use of permits as a control designated as ERDA WASP Air Priorities Offices to device in order to relieve and prevent - function in the context reflected in the WASP Air congestion in ports and interior storage Priorities Manual. Managers of Deld offices and.the areas. Subsequent to initial full embargoes, Director, Division of Administrative Services, are shipments are controlled by various methods delegated authority to redelegate to ERDA personnel under each of the above orders as follows: only responsibility to act as the ERDA Administrator '(1). lCC TM 2 " Rail Freight Embargo'? of Air Priorities for offices and contractors within 4 i provides controls over the movement of their jurisdictional area. Requests for Class I ,M rail. and rail '. express traffic. The priorities shall be referred to the Director, Division of f Chairman of the Car Service Division,' Environmental Control Technology, for appropriate j3 ' Association of American Railroads, is handling with the WASP Air Priorities board. d"

[ ' Approved: July.14,1975'

~ 34 $.d

ERDA Appendix 5201 Annex B TRANSPORTATION OF PROPERTY S. PREFERENCE AND PRIORITY SYSTEM emergency transportation control authorities, and ERDA Headquarters, as Managers or ' field offices who have routing necessary, in order to assure receipt of responsibilities shal! estaulish a preference and up-to date information on carrier and priority control system for the transportation of their consignee transportation capability. sponsored material which will (a) assure availabliity of material in support of essential programs, and (b) b. Emergency Shipments. ERDA and cost type be consistent with preference and priority controls contractor shipments will be made only to which may be established on a nationallevel, the extent that the transportation emergency and national controls impcscd on commercial transportation systems will 7. ERDA PERMIT CONTROL SYSTEM permit. Less essential shipments should be deferred pending relief from the emergency Current local routing practices which control the conditions. transportation of ERDA and ERDA sponsored freight by commercial carriers will constitute the ERDA's c. Form of Permit internal permit control system du.ing emergencies. Permit procedures relating to each mode of (1) Each field office shall use a permit form transportation will be compatible to some degree, which will meet its immediate and The staff nucleus for the ERDA WASP Air Priorities singular requirements. Office will assume permit responsibilities for all (2) The form of the permit to be used shall categories of transportation. The form of the actual be generally in consonance with and permit used, where applicable, should under all contain provision for submission of all conditions clearly indicate that the shipment is data categories which may be required a u t horIzed under applicable emergency by emergency transportation regulatory authorities on a national level in the D transportation authorities. exercise of their co nt rol over a. Information Essential to the Permit Control transportation by common carriers Sy s t e m. Com plete knowledge of the during periods of emergency. capability of carriers to orform the (3) Except for the WASP control system 1 transportation se r vices and of the which contains suggested permit forms, consignee's capability of receiving the the emergency transportation regulation material is necessary so that permits may agencies have not prescribed a specific appropriately be issued to allow for permit form. transportation of ERDA and cost type (4) Field offices will be advised when such contractor shipments. Necessary liaison forms have been prescribed by subject i should be maintained with carriers, regulatory agencies. D 35 Approved: July 14,1975

w TRANSPORTATION OF PROPERTY ERDA Appendix 5201 ANNEX C AGREEMENT BETWEEN THE GENERAL MANAGER AND THE DIRECTOR OF REGULATION FOR PACKAGE DESIGN REVIEWS l !~

1. " +,

UNITED STATES [ ATOMIC ENERGY COMMISSION f \\;1y') L I WASHINGTON, D.C. 20545 I

• i-t Agreement Between the General Manager and the Director of Regulation for Package Design Reviews The General Manager and the Director of Regulation agree to the following procedures for obtaining Regulatory staff review of safety evaluations of designs of packages to be used by license-exempt AEC contractors for the shigeent of Type B, large quantity, and fissile radioactive materials.

This agreement does not apply to package design reviews for nuclear weapons and explosives, and related components. For this purpose, the Division of Waste Management and Transportation (WMT) !s the point of contact for the General Manager's staff and the ' Directorate of Licensing, Deputy Director for Fuels and Materials, is the point of contact for the Regulatory staff. Each General Manager request for Regulatory review will be accompanied with: Three copies of the Safety Analysis Report for Packaging (SARP), a. prepared and processed in accordance with AECM 5201. b. The interim Cert.ificats of Compliance (Form AEC-618) and any amend-ments thereto. The priority assigned for the safety evaluation of the package design. c. 37 Approved: July 14,1975.

ERDA Appendix 5201 Annex C TRANSPORTATION 0F PROPERTY Upon receipt of the above information, Regulatory will: a. Schedule the package review and advise the General Manager of its schedule. b. Review the information provided and determine whether the design ,l meets the requirements of 10 CFR Part 71. The depth and extent of the Regulatory review will give consideration to the review conducted by the GM field offices pursuant to AECM 5201. c. Issue a memorandum to the General Manager stating the results of the review, including a request for additional information if necessary. A copy of the Certificates of Compliance, and any amendments thereto, issued by the General Manager for such packages will be forwarded to ) ' Regulatory. N/Yh ,h h YL:u[ Dated _ / / Robert E. Hollingsworth Acting ' General Manager h' Ul w h 73 \\b Dated DirectorofRegula{ig L.ManninhMuntzi , Approved: July 14,1975 38

TRANSPORTATION OF PROPERTY ERDA Appendix 5201 ANNEX D GUIDE FOR PREPARING SAFETY ANALYSIS REPORTS FOR PACKAGING 1. INTRODUCTION included, along with whatever tables, graphs, . drawings, pictures, and technical references A Safety Analysis Report for Packaging (SARP) is are necessary to give a clear treatment of the required by ERDAM 0529 for packaging of fissile subject. material, more than type A quantities of other C, The quality assurance program should be radioisotopes, and mixtures of both. The purpose of described as it applies to the particular this guide is to furnish guidance and assistance in the packaging including designer, fabricator, and preparation of the SARP, user responsibilities. Procurement responsibilities include the specification of As a minim um, the SARP must meet the quality assurance requirements in requirements set forth in appendix 0529, part procurement documents, provide for IV.F.2.; however, to expedite Nuclear Regulatory surveillance of fabricators' tests and review Conunission (NRC) review where such review may be of related records, and contain inspection necessary, the SARP preparation should follow the - criteria and procedures for received items. basic sequence of 10 CFR Part 71, sections 71,21 to 71.24. Typical user responsibilities are procedures and policies regarding perfonnance of The SARP should contain sufficient information for scheduled, periodic inspection, critical parts avaluation in five primary categories: structural replacement, use of checklists for loading, integrity, thermal resistance, radiation shielding and and retesting reusable containers and should D qaality assurance. radiological safety, nuclear criticality safety, and be described. D. The SARP must be a bound, distributable The amount or information and the extent of the document which is, or may become, part of SARP detail will vary depending upon the proposed the documentation required in appendix package. If portions of the information required to 0529, part IV,F. It must be prepared and,if meet appendix 0529, part 11, do not apply to a unclassified, submitted to the Technical specific package, the SARP should so state, When Information Center in accordance with completing the supporting information in the sections appendix 0529, part IV,F., for reproduction 10 CFR 71.31 to 71.40, if a particular standard does and distribution based on need. not apply to a specific package,it should be indicated "not applicable," lll, SARP CONTENTS-SPECIFIC

11. S ARP CONTENTS Based on previous reviews of SARPs by both NRC and ERDA staff, the following details should be

.i A. The report shall include a complete physical included in the SARP: and technical description of the proposed package design h enough detail to provide a A. Description of Packaging. The description basis for evahration of the packaging. The should include data on the gross weight, in for ma tion required is described in model number, materials of construction, appendix 0529, part iV.F.2., and in 10 CFR materials used as neutron absorbers or 71.22. moderators, external dimensions and cavity B. A package evaluation to demonstrate that size, internal and external structures, the package satisfies the standards specified receptacles, valves, sampling, ports, in appendix 0529, part !!, may consist of structural or mechanical means of heat subjecting a sample package to actual dissipation, volumes and types of coolant, conditions specified, or it may consist of any outer and inner protrusions, lifting and other assessment such as an analytical tie down devices, amount of shielding, D evaluation or testing of a prototype or seale pressure relief systems, closures, and means model of the package. Pertinent data on of containment. It is important that the analytical methods and test results should be closures be described well enough to 39 Approved: July 14,1975

3 ~ EP,DA Appendix 5201 Annex D TRANSPORTATION OF PROPERTY i evaiuate their performance in accident test models, techniques and procedures must conditions, be described in sufficient detail to establish the adequacy of the tests. B. Contents of Packaging. Describe the quantity of isotopes, maximum amounts of The maximum accelerat'on of a cask in radioactivity, chemical and physical form, each impact position of the tests should material density, moderating ratios, be justified. configurations as required for nuclear safety j evaluation, the maximum amount of decay "The selection of the position for which ~ heat, maximum pressure build.up in the maximum damage is expected" must be inner container, leak tests, and any loading justified for each evaluation of impact restrictions and limitations. and puncture required by appendix C. Normal Conditions of Transport l. Heat Tmnsfer Analysis. The SARP must If bonding is claimed to exist between present either an evaluation and analysis the lead and the steel, state the value of of the heat transfer considerations or the ultimate bond stress and explain test results which demonstrate that the how this value was determined. cask when loaded with its design contents complies with the regulations. Where bolts are used to secure a cover, The maximum temperatures of the cask show that the bolts will not fait during a components and contents shall be top corner or a side drop. This analysis determined and compared with the should consider both that component of permissible limits in the regulations. the impact force from the covei and c ntents which ac ts along the The thermal performance of the cask for hot. day (100 F) normal conditions I ngitujinal axis of the cask and the sheer force which acts m, ti,e plane of of transport case, clearly showing the the cover. contributions of source heat, solar heat flux, and convection in the heat balance equation, must be evaluated. The results In cases where trunnions are an integral should be related to the cask internal Part of the packaging, show that the pressure for normal conditions. welds which connect the trunnion to the bracket p tes and the :ower 2. Shielding. Shielding calculations or tests reinforcement p te are strong enough used to establish the thickness of the to prevent failure and penetration of the gamma and neutron shielding must be cask during impact by failed trunnion presented to determine the dose rate 3 parts. feci (or I meter) from the packaging surface for both the normal conditions if a ciash shield is designed to be of transport and the accident test integral with 1.e cask, show that it will conditions, remain in pbce during a 30 foot drop in any position. D. Accident Damage Tests 2. Thermal. Describe the test used to 1. Structural. The design shall demonstrate determine the overall heat transfer that the cask would comply with the coefficient for the cask. The effects of accident condition requirements of the external environment should be appendix 0529, part 11 and 10 CFR excluded from the co e fficient 71,36. The evidence presented may be determined. Ambient conditions for the engineering calculations test results, or package prior to the fire test may be substantiated engineering logic. The assumed to be 100 F. applicability of both manual or computer techniques to the problem Estimate the extent of melting which -) shall be established. If full size or scale could occur in the lead shield during the model testing is utilized, the test hypothetical fire accident. This should Approved: July 14,1975 40

i 4 ERDA Appendix 5201 TRANSPORTAT10N OF PROPERTY Annex D consider the fire in conjunction with E. Calculational Methods. With the assistance internal heat load and show that of consultants in some cases, NRC reviewers adequate shie' "ng will remain.- develop calculational methods (including complex computer programs) for analyzing The amount of intervening shielding the structural, thermal, shielding and assumed following the accident criticality aspects of package designs. The conditions should be justified by staff uses these methods to perform i structural and thermal analyses. Independent analyses of package designs to Consideration should be given to verify the adequacy of the analyses and leakage of molten lead and the

results, resolidification of the lead.

Currently the NRC staff is using the ORNL Isotope Generation and Depletion Code to Show that the pre ence of other fuel determine source terms for our shielding pins or sources does not increase the a nalyses. Shielding analyses are being heat generation in each of the fuel pins performed using ANISN, DOT, and MORSE in the package. p rograms depending on the modeling requirements of the problem. A 2218 Where rupture disks are designed in a coupled neutron and gamma ray cross package, provide and justify section library is used in the shielding specifications for the rupture disk, calculations. Criticality analyses are shc> wing the design burst pressure, and performed almost exclusively with the the ' probability of a burst occurring KENO Monte Carlo program although above or below this design pressure. ANISN and DOT may also be used. The c ross section sets used in criticality 3. Nuclear Criticality. Proof must be calculations are the 16 group Knight modified 9 presented that the cask contents will (ORNL) llaasen Roach for homogeneous remain subciitical under both normal systems and the 123 group GAM. The latter and accident conditions.The proof may set,is rcs uance c trected, cell weighted and reduced n to 16 groups by the XSDRN be an analvtical calculation or the Pmgrandodettemgeneous fud regions. results of a substantiated experiment. lf suberiticality of the contents depends F. References on geometric spacing or the presence of neutron absorbers, the integrity of the 1. ANSI Standard 14.12 for packaging and spacing structure or the absorber under package design requirentents (in both normal and accident conditions preparation). s h all be established, Detailed 2. Cask Designers Guide, ORNL NSIC.68, requirements for criticality evaluation "A Guide for the Design, Fabrication, are described in ERDAM 0530, and Operation of Shipping Casks for " Nuclear Criticality Safety;" appendix Nuclear Applications." 0529, part li,C,; and in 10 CFR 71.36 3. Preparation SARP for 10 CFR 71 to 71,40. (Guide in preparation). l 41' ~ Approved: July 14,1975

l w o D ' TRANSPORTATION OF PROPERTY ERDA Appendix 5201 EXHIBIT 1 CERTIFICATE OF COMPLIANCE ,o,. g n oa.g i, U.S. ENEROY RESE ARCH AND DEVELOPMENT ADMINISTRATION (8 85) CERTIFICATE OF COMPLlANCE 16 CP R f t EftOAM t at t For Radioactaw Meteriais Packages m la. Certificate Number Ib. Revismo No. Ic. Package identificaten No. Id. Page No, le, Total No. Pages. 2, PREAMBLE 2a. This certificate is issued to satisfy Sections 173 303e,173.394,173.396, and 173.396 of the Department of Transportation Hazardous Materiais Regulations (49 CF R 170-189 and 14 CF R 103) and Sectsons146-1910e and t46-19100 of the Department of T'ansportation j Dangerovs Camoes Regulatmos (46 CF R 146-149), as emended. 20. The packaging and contents described 6n item 6 below, meets the safety standards set forth in Subpert C of Title 10. Code of Federal Regulations, Part 71,"* Packaging of Radioective Material for Transport and Transportation of Radiosetive Material Under Cartain Cond.t ens." 2c. This certificate does not re'eeve the consignor from compliance with any requirerrwit of the regulations of the US. Department of Transportatron or other applicable regulatory agencies, including the governenent of any country throw 0h or into which the package will be transported.

3. TNs cartocata is issued on the basis of a safety analysis report of the package design or application-(1) Prepared by IName and addressJr (2) Title end Identification of report or application:

(3) Date-D 4 CONDITIONS e This certificate 6s con.htional upon the fulfilling of the requirements of Subpart D of 10 CF R 71, as appliesbie, and the conditions specefied in item 5 below.

5. Deserintion of Packaging and Authorized Contents, Model Numeer, Fissile Class, Other Condetions, and Ref erences:

~ \\ \\ \\ 6e Deie of lesuance: l 66. Espershon Date: FOR THE U.S. ENE RGY RESE ARCH AND DE VELOPMENT ADMINISTR ATION 1a Arktrut lof EROA iswmg Officel

16. Signature,Name,and Tittelof EROA Aporovmq Ottocial)

\\ D 43 Approved: July 14,1975 '}}