ML20197B261
| ML20197B261 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1986 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8610280318 | |
| Download: ML20197B261 (2) | |
Text
_ _ _ _
onynal i
00T 16 m3 MEMORANDUM FOR: Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety Office of Nuclear Materials Safety and Safeguards FROM:
Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards *
SUBJECT:
STANDARDS REVIEW REQUEST - N-14.2 We have reviewed the proposed standard ANSI N-14.2, "Tiedown for Truck Transport of Radioactive Materials," as forwarded by your memorandum of September 15, 1986.
The following comments on the proposed standard are provided for your consideration.
1.
As written, the Standard only addresses a small category of containers to be shipped by truck, e.g., vertical containers.
This would apply to waste casks or some spent fuel casks.
However, there are other containers which meet the scope of the standard (" packages weighing one ton or more and which are marked or labeled ' Radioactive'"), and which are shipped in a horizontal position. Examples of these containers are 48-X cylinders or 30-A cylinders with 21-PF-1 overpacks for the shipment of uranium hexafluoride.
The Standard should address tiedowns for horizontal packages.
2.
The Standard addresses the situation where only one container is loaded on the trailer.
There are multiple examples where more than one container is shipped at a time, such as uranium hexafluoride cylinders, or unirradiated LWR fuel assemblies, where the containers are stacked. Under the provisions of the standard stacked containers would no longer be allowed since the base of the top container could not be bolted to the trailer base.
The standard should address multiple package shipments.
3.
The Standard uses the term " worst non-accident event" in establishing the tiedown requirements.
49 CFR 173.425 uses the term " conditions normally incident to transportation."
It appears that " worst non-accident event" is intended to describe or define " conditions normally incident to transportation."
If so, the standard should clearly state this.
4.
Section 4.1.6 of the Standard states that proper placement of the load to achieve regulated axle loadings is the responsibility of the carrier.
49 CFR 173.425 makes the loading of the shipment the responsibility of the consignor.
The responsibility for proper loading of the shipment should be clarified so that it is consistent with the D0T regulations.
8610280318 861016 PDR j6
$02 g
't 0
o
Charles E. MacDonald 2
5.
Section 4.1.8 of the Standard requires that the shipper and the carrier reach an agreement in writing as to which one is responsible for installation and inspection of the tiedowns.
However, the D0T regulations place the responsibility for preparation of shipments with the shipper.
Should a problem develop in transit, the NRC and/or the various states would take enforcement action against the shipper regardless of any " written agreements."
The subject of securing packages or containers during shipment is one which needs to be addressed and we encourage the issuance of guidance.
However, for the reasons previously noted, the draft Standard does not address the spectrum of containers or configurations presently being shipped.
If a standard is to be issued for each configuration, the industry will be overwhelmed in paper.
A single standard should address the design parameters, such as Section 4.1.1, and require that each shipper develop a program (which would include analysis methods, tiedown schemes, evaluations, etc.) to cover his particular situation.
The specifics or examples could then be appendices to the Standard.
The specifics would then include vertical and horizontal containers, multiple containers, etc.
If you have any questions on the above comments, please give me a call.
Douglas M. Collins
(
bec:
R. Bellamy, RI W. Shafer, RIII I
W. Fisher, RIV F. Wenslawski, RV I
l l
i I
RII RII GTr CH l
1 i/6 p10/f/86 f
i l
l i