ML20217G653
| ML20217G653 | |
| Person / Time | |
|---|---|
| Issue date: | 05/13/1997 |
| From: | Jackie Cook, Easton E, Pope R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), OAK RIDGE NATIONAL LABORATORY |
| To: | |
| References | |
| NUDOCS 9804290182 | |
| Download: ML20217G653 (15) | |
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4th Internati:nal C:nfirenes en Transportation fer ths Nuclear Industry
! B:urnimauth, England, May 13-15,1997 Development of guidance or. applications of regulatory requirements for regulating large contaminated equipment and large D&D components Ronald B. Pope Transportation Technologies Group Oak Ridge National Laboratory2 j P.O. Box 2008 Oak Ridge, Tennessee 37831-6495, USA Earl P. Easton and John R. Cook Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop 06G22 I Washington, D.C. 20555, USA Richard W. Boyle l Research and Special Programs Administration ;
U. S. Department of Transportation l
400 Seventh Street SW Washington, D.C. 20590, USA 4
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The views expressed in this paper do not necessarily represent the siews of the U.S.
Nuclear Regulatory Commission, the U.S. Department of Transportation, or the Oak .
G l Ridge Naticnal Laboratory. q \
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Oak Ridge National Laboratory is managed by Enc 1 chard Martin Energy Research under contract DE-AC05-960R22464 with the U.S. Department of Energy.
9804290182 970513 PDR ORG NOMA PDR
ABSTRACT- 1 In 1985, the International Atomic Energy Agency issued revised regulations for the safe transpon 4 ofradioactive material. Significant were major changes to requirements for Low Specific Activity (LSA) material and Surface Contaminated Objects (SCOs). As these requirements were adopted into regulations in the United States, it was recognind that guidance on how to apply these requirements to large contaminated / activated pieces ofequipment and D&D objects would be needed both by the regulators and those regulated to clarify technical uncenainties and ensure implementation, . Thus, the U.S. Depanment of Transponstion and the U.S. Nuclear Regulatory Commission, with assistance of staff from Oak Ridge National Laboratory, are preparing regulatory guidance which will present examples of acceptable methods for demonstrating compliance with the revised rules for large items. Concepts being investigated for inclusion in the pending guidance are discussed in this paper. Under current plans, the guidance will be issued for public comment prior to Snal issuance in 1997.
INTRODUCTION The U.S. Department of Transportation (DOT) [1] and the U.S. Nuclear Regulatory Commission (NRC) [2] regulatiohs for transponation ofradioactive materials, revised for compatibility with those of the 1985 version of the Internationa! Atomic Energy Agency (IAEA) [3] regulations,
, became effective 1 April 1996. The revisions changed the regulatory fra:nework under which j Low Specific Activity (LSA) material and Surface Contaminated Objects (SCOs) are characterized, classified, categorized, packaged and transported. In addition to affecting many smaller shipments in the United States, these changes will impact the manner in which large objects which are contaminated, activitated, or both are prepared, packaged and transported.
Many such objects are expected to arise in the United States in the future either as a result of maintenance scitivities related to the continued operation of nuclear-related facilities, or as a result of decommissioning or decontamination (D&D) activities associated with shut-down of old facilities. Because the new regulations represent a substantial change from their predecessors, many questions have arisen from the community ofindividuals who must ship or who regulate j shipment activities relative to the classification, pre-shipment processing, handling, packaging, and i transpon of large objects which might be classified as LSA materials or SCOs.
Under the revised regulations, it would be useful to consignors and regulators alike to have guidance on approved methods for preparing, classifying and packaging large objects - such as L steam generators (SGs), reactor pressure vessels, pumps, and large D&D items - as LSA materials or SCOs. This will facilitate compliance, assurance, ensuring workers will not receive unreasonable or unnecessary radiation exposure, keeping such exposures as low as reasonably
, achievable (ALARA), and reduction of the administrative burden on both consignors and regulators relative to such shipments.
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JOINT NRC-DOT DRAFT GUIDANCE In order to address the questions which have been raised regarding the proper and consistent implementation of the new LSA material and SCO requirements specifically as they apply to large objects, and at the request ofindustry in the United States, NRC and DOT will be issuing joint guidance on the packaging and transport of large contaminated / activated objects and pieces of equipment in the near future. In addition, separate and complementary guidance is being ,
developed for LSA material and SCOs in general; this activity is discussed in a companiori paper at this conference (4).
This paper presents initial thoughts on the content of the joint guidance being considered for publication by NRC and DOT; it describes some of the questions and the corresponding guidance under development. Current plans are to issue thejoint guidance, in draft form, for public comment in 1997. As a result of the public comments, peer review, and internal discussions, the content of both the draft and final guidance may be significantly different from that presented in this paper.
The guidance being developed will provide the framework which a consignor may use to either ;
classify and package large objects for shipment in full compliance with the regulatory l requirements; or seek regulatory relief through the exemption process by demonstrating equivalent levels of safety for the requirements set forth in the regulations. Included in the
! development of the guidance has been a review of practices which have been previously followed I
in preparing, packaging and shipping large objects; development of proposed definitions for application within the guidance, and methods to be used for satisfying the clusification, l
preparation, packaging, and transport regulatory requirements for large objects.
In anticipation of ultimately issuing this document, the NRC issued, in late 1996, a policy issue (information) document with an attached NRC Generic letter, providing interim guidance on the l transportation of one category oflarge, contaminated objects - steam generators (5]. This documented steps required to allow SGs to be shipped, noting that if a steam generator were classified as an SCO and, in particular satisfied certain requirements relative to unshielded dose 1 l rate, it could be shipped as an SCO and would not require NRC package certification. This was a l change relative to previous practice within the United States. The guidance being considered also addresses the issue of shipping large objects unpackaged, which was addressed in Reference 5.
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l BACKGROUND '
Prior to implementation of the 1985 Edition of the IAEA Regulations [3], SCOs were treated as a subcategory of LSA material. For large contaminated objects, U.S. consignors historically determined the quantity of radionuclides present on their surfaces, estimated the average concentration of the radionuclides per area of the contaminated object and classified and shipped 1
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them as LSA material. This practice proved to be convenient and efficient for consignors and regulators for several reasons, including:
(a) the structural integrity of many types oflarge pieces of contaminated equipment and large components was such that the equipment or object itself, with only minor modifications, could often served as its own packaging; (b) extensive intemal decontamination oflarge pieces of equipment and large objects was not always necessary prior to shipment and, if performed, could have resulted in significant exposure of personnel; and (c) general radiation surveys of such large items, combined with process knowledge and reasoned argument were often used to assess, or estimate, the total quantity of contamination that was present for a package's contents.
With the new regulations, a " surface contaminated object" (SCO) is now identified as a separate category for transport in non-accident resistant packages (i.e., industrial packages (IP-1, IP-2 and IP-3 [3]) and, in the United States, in Type A packages as defined in 49CFR173.403 [2)}.
Specific conceptual models of SCO behavior under various conditions were developed [6] to estimate maximum levels of surface contamination that would provide approximately the same level of health protection for a member of the public as that afforded by a Type A package containing an A2 quantity ofradionuclides.
Because SCOs are now a completely different category from LSA material, and are no longer considered a subset of LSA material, it was determined in the U.S. that guidance on approved operating procedures for large objects was needed. In addition, guidance was needed on satisfying, for large objects, the requirement that the radiation level 3 m from the unshielded radioactive material, object, or collection of objects classified as LSA material or SCOs shall not exceed 10 mSv/h (I rem /h). This determination has radiation protection implications specifically related to demonstrating compliance with this requirement in practice without incurring unreasonable personnel exposure.
Furthermore, once the object is classified, it must then be properly packaged for shipment. The objects considered in this paper can be extremely large. For example, SGs, pressure vessels and some other large objects can exceed 180 metric tonnes, and may require use of packaging which goes far beyond that which is commercially available to consignors of radioactive material or may not be realistically capable ofbeing packaged at all using common packaging procedures. In these cases, special preparations, consideration of packaging requirements, and alternate methods for providing adequate levels of worker and public safety, and special operational controls are expected to be required for shipment.
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i-l The guidance being developed is expected to establish reasoned and practical approaches for l defining "large" (in the context of "large contaminated and/or activated object"); establishing l bases for classifying outage and other large equipment and objects (e.g., pumps, SGs, and reactor vessels) as LSA materials or SCOs; defme practical methods for determining the extent to which the internals of the equipment or object may be contaminated, and for treating - from a l regulatory standpoint - residual liquids that might exist in the inaccessible parts of the equipment l (e.g., pump mechanisms) or object; establish and document a generic approach that might be used
! for seeking regulatory relief through the U.S.-regulatory exemption process when an object cannot be packaged in conunercially available packaging or subdivided into smaller elements for packaging; and establish approaches for satisfying requirements in the regulations pertaining to contamination and radiation level determinations on large pieces of equipment and objects.
l DEFINITIONS In order to address issues relating to large objects, it was necessary to provide - for the purposes i of the guidance being developed - definitions of some key terms. Other related definitions were l developed for the more generic LSA material and SCO guidance being developed, and these were discussed in Reference 4. The key definition for the large objects is to clearly specify what is meant by large. To that end, consideration is being given to defining the term large as:
l Large (as used in large object or large piece of equipment) means an object or piece ofequipment which (a) can be classified as either LSA material or SCO, and (b) because of size, weight, geometry, or construction or physical makeup, is not practically divisible into smaller entities for packaging and transport; l
and (c) because of size, weight, or geometry, cannot be readily packaged using commercially available packagings that satisfy the requirements for containing LSA material or SCO as required in DOT and NRC regulations; and (d) is therefore prepared for shipment either (i) in alternative, custom packaging which is demonstrated by the consignor to comply with the applicable regulatory requirements, or 4
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l (ii) in an unpackaged state, with appropriate safety control measures to l
compensate for not placing the object in a packaging approved by !
the appropriate regulatory authority. !
i In addition, because the terms practically divisible and commercially amilable packaging are i used in this definition, these terms will also be defined. Included in the definition of the former l will be a criterion addressing the need to keep the exposure ofworkers ALARA when considering l whether an object is practically divisible. If excessive exposures are expected to be incurred, '
l then the consignor should consider shipping the object as a large object following the guidance being developed. Relative to commercially amilable packagings for a large object, the definition !
will address the issue of size, where a packaging with external dimensions not exceeding those of a standard ISO-container would be deemed to be commercially available. However, it will be i noted that the assessment of what is commercially available must be left to the consignor. - If an l "off-the-shelf' packaging is not commercially available, the consignor then may either apply the procedures defined in the large object guidance; or - if practical - choose to custom-build a !
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- packaging, possibly on a one-of-a-kind use basis, and demonstrate that it satisfies the applicable ;
packaging requirements.
METHODS AND ALTERNATIVES FOR TRANSPORTING LARGE OBJECTS Although many large objects may not be practically packaged for transport, compliance with the technical requirements of the regulations is necessary. In the United States, compliance with all I requirements must be achieved unless certain requirements are specifically exempted by the DOT. l As noted above, some objects may be so large, massive, or of such configuration that l commercially available (even custom) packaging may be impractical. In addition, the physical and radiological characteristics of such large objects may often make it impractical or injudicious to !
directly measure associated concentrations and distributions of radioactive materials. This is not to say that these objects cannot be transponed safely. Examples oflarge objects that have been l transponed which required exemptions from the U.S. regulatory requirements include the i i Shippingpon Reactor pressure vessel [7] (Ref. I1), and Yankee Atomic's Yankee Rowe and Portland General Electric Company's Trojan SGs (8). SGs might be considered as surface contaminated objects [5], where they would be required to be shipped in an IP as a minimum.
However, an SG which has its outer shell penetrations welded shut may be deemed to be as robust as (or more robust than) an IP. In this event, a consignor may apply to DOT for an exemption to the packaging requirement.
l l The guidance being developed is expected to suggest that technical and administrative means will I
be acceptable if these means:
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(a) demonstrate levels of public safety equivalent to those that would be achieved if compliance with the requirements of the regulations were i possible, and (b) ensure consistency with provisions of hazardous materials transponation j law.
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I Specifically, the guidance is expected to discuss alternative approaches which may be employed in
! characterizing large objects as LSA materials or SCO; present guidance on preparing large objects for shipment including preparations that enhance packaging functions of the large objects; examine alternatives for packaging large objects; and provide guidance for consignors who apply to the DOT for exemptions from the requirements of the Hazardous Material Regulations.
l Characterizing Large Objects The provisional guidance discussed here will first be directed toward assisting in the characterization oflarge objects as LSA material or SCO. Clearly, in order for large objects to l qualify as LSA material or SCOs, the object must satisfy the limits for LSA material and SCO
- given in their respective definitions. Otherwise, a large object whose contamination levels exceed l
SCO limits or whose average specific activity exceeds the limit for LSA material must be classified as radioactive material, n.o.s. as appropriate.
Practical characterization approaches are needed for satisfactorily determining (a) the specific activity of a large object; (b) the levels offixed and non fixed contamination on surfaces (both accessible and inaccessible); (c) radiation levels for the unshielded item; (d) the radiation levels at those positions external to the package, prior to shipment, where radiation level limits are specified in the regulations; and (e) for determining the leachability for LSA-III material. In order to make these determinations safely and at reasonable cost, the guidance is expected focus on:
e the need to keep personnel exposures ALARA; e
the impact different packaging and transpon alternatives will have on potential exposures to workers and public as well as potential risks to workers, the public and the environment; and e
the relationships between the waste acceptance criteria (WAC) if the material is to be disposed of, pre-shipment processing, transpon packaging, transpon, post-shipment processing, and disposal packaging.
The guidance being considered for large objects is expected to address the general issues listed above as they relate to a large object, and is expected to provide practical approaches for addressing each. In addition, it may also address specific characterization issues such as those relating to an object which is contaminated with materials having an unlimited A2 value (such as 6
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l those arising from the D&D of mining, milling, feedstock, and uranium enrichment facilities). The type ofguidance being considered is discussed below for two of the generic characterization issues only.
Practical Approaches for Determining Radiation Levels at 3 m from an Unshielded Large Object. Regulatory requirements now limit the dose rate external to LSA materials or SCOs to 10 mSv/h (I rem /h) at 3 m from the unshielded contents as a limit on the amount of radionuclides available for release in the event of an accident. The issues associated with physical measurement of dose rate are based on two fundamental concerns: (a) limiting worker exposures to ionizing radiation to levels that are ALARA and (b) controlling costs associated with transportation oflarge LSA objects classified as LSA materials or SCOs. Physical radiation level measurements for numerous large cMeet shipments could lead to substantial dose commitments for the radiation worker populat:on, possibly being inconsistent with the goal of keeping exposures to ionizing radiation of workers ALARA. In order satisfy ALARA requirements, the following methods are being considered for recommended use:
- the taking of a few spot radiation measurements; e extrapolations and calculations; l reference to a previous, satisfactory compliance demonstration of a sufficiently similar object that had operated under similar conditions; t
a process knowledge; a remotely taken, direct measurement; or l
a combination of the above.
l Practical Approaches for Determining Contamination Levels far Large Objects.
Regulatory requirements address the limits for fixed and non-fixed contamination on accessible i and inaccessible surfaces of SCOs. In determining complitnce with contamination limits, l consideration is being to to providng guidance as follows:
l (1) For accessible surfaces of objects, where the contamination levels are I specified, it is up to the consignor to establish the basis for and document <
the wipe efficiency used to determine the contamination levels on these objects. Otherwise, the consignor will need to document that the default ;
value of 10 percent (as specified in Appendix II of Reference 6) has been used.
(2) Removable contamination on external surfaces may be fixed in place using a weatherproof coating or paint. The coating or paint must be shown to 7
l limit contamination to levels as appropriate in 10CFR71.87 and 49CFR174.443 immediately prior to transportation. Any shielding effects i of the coating or paint must be accounted for in determining compliance
! with SCO limits.
l l (3) ' Removable contamination on internal surfaces (accessible and inaccessible) l can be fixed and made inaccessible through the use ofcement, grout or other binding agent. Any surfaces made inaccessible must be shown to meet the appropriate contamination limits for SCO prior to adding grouting or binding agents.
(4) Large objects with external contamination must not exceed applicable l limits at any time during transportation.
In developing this guidance, U.S. regulators recognize that, in practice, there will be many instances where accessible surfaces of an object are contaminated with both fixed and non-fixed contamination, and the contamination which is determined to be fixed prior to shipment will remain fixed during normal transport. However, there may be instances where what is determined to be fixed contamination on the accessible surfaces of an object prior to shipment may become non-fixed during transit. Thus, the guidance will probably indicate that account should be taken prior to dispatch of any object that might be subject to this phenomenon to ensure that the object remains within compliance throughout thejourney.
A number of methods can be used when evaluating fixed and non-fixed contamination levels on external surfaces of SCOs as outlined in the generic guidance (discussed in Reference 4). It is expected that the guidance being developed will consider each of these and provide direction to both consignors and inspectors on the preferred methods to be used for four specific situations:
l (1) accessible surfaces, non-fixed contamination; (2) accessible surfaces, fixed contamination; (3) accessible surfaces which will be made inaccessible prior to shipment, both fixed and non-fixed contamination; and l i (4) inaccessible surfaces, both fixed and non-fixed contamination.
Packaging Large Objects A large number of packagings are readily available from commercial sources which can be used to ship LSA materials and SCOs; however, as the size and mass of objects increase the choice of readily available packagings disappears. As a result, attemative approaches are required, and they l 8 I
may entail (a) providing custom packaging that meets all applicable requirements of the regulations; (b) providing custom packaging that is exempted from one or more of the l
regulatory requirements; or (c) demonstrating that the large object meets some or all of the applicable regulatory packaging requirements.
irrespective of the approach taken by a consignor, the general packaging requirements for radioactive materials provides the basis for their safe transport and the manner in which these j requirements are satisfied should be documented for any custom-built package meeting all of
- the requirements of the regulations [as in (a) above), or referenced in any application for exemption [as in (b) or (c) above). The guidance being developed is expected to focus on each of the three alternatives available to a consignor of a large object, and provide specific insight into and examples of methods to demonstrate how each situation may be handled.
The basis and detailed requirements for an exemption application to DOT are clearly specified in the regulations. For example, for large objects which qualify as LSA material or SCO shipped by exclusive-use vehicle, the application would need to demonstrate safety equivalent to that provided by a strong, tight packaging. In addition, for large objects whose contents do not exceed an A2value per package, the proposed packaging should demonstrate substantial compliance with the Type A package requirements. -
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Consideration is also being given to providing guidance on the use of cement grout (grout) and l binding agents to prepare large radioactive or contaminated objects for transportation and for subsequent disposal. The three principal purposes of binding agents may be considered to be to (1) fix contamination, (2) provide shielding to reduce radiation levels, and (3) provide structural support. Although the use of grout and binding agents in general will be covered in the generic LSA material and SCO guidance (4], the use of these agents, and unique problems associated with their use in large radioactive or contaminated objects, will be addressed.
Esemptions for Transport of Large Objects As has been noted earlier, because of the size, weight, geometry, or construction or physical makeup of the large objects considered in this document, these objects will frequently be such that (a) they cannot be practically subdivided into smaller entities, (b) they would result in being l shipped as an " OVERWEIGHT" or " OVERSIZE" shipment, and/or (c) they cannot be readily packaged using commercially available packaging. In some cases, especially those cases where packagings may not be commercially available, it may be necessary to seek an exemption from the appropriate regulatory authority.
- Specifically, in the United States, the DOT regulations specify that a shipment of unpackaged ,
. radioactive material is not allowed unless relief from the packaging requirement is obtained. j Cases exist where an object is of such a robust nature that packaging in, for example an Industrial i Packaging, would prove to be superfluous (see, for example, issues related to pressure vessels j [7]). Consider, also, an SG, where, ifit is seal-welded closed, then the thick-walled outer 9
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4 stmeture of the SG would in all likelihood be more robust than any Industrial Packaging into which it might be placed. In this event, it would be incumbent upon the consignor to demonstrate, in an application for exemption, that the seal-welded outer structure of the SG provides safety equivalent to that which would be provided by an Industrial Package.
The DOT and NRC regulations specify what must be satisfied to obtain " administrative relief... l on the basis of equivalent levels of safety or levels of safety consistent with public interest" and with applicable DOT policies. This administrative reliefis known in the United States as an exemption. In some cases, a consignor may be faced with multiple shipments of similar large 1 objects. In this case, the regulations suggest that the consignor may seek a single exemption which will cover multiple shipments oflike nature. This is to be accomplished by including a specification in the application for exemption the proposed duration or a description of the proposed schedule of events for which the exemption is sought.
For very large items having dimensions or weight which would not allow them to be placed in readily available commercial packagings, then an exemption may need to be sought from DOT or !
the NRC (depending upon the total activity of the radionuclides involved, etc.) to ship the object ]
"unpackaged." In this event, because the object is not to be placed in a packaging, or because attemative packaging-like materials are added to (e.g., sealed closures on penetrations) or around ,
the outer structure (e.g.,61 ament-reinforced plastic sheeting), the request for exemption should l document the basis - through analyses, testing, reasoned arguments or combinations thereof- !
that the proposed steps to be taken in preparing the object for transport, and any safety control l measures deemed necessary, will achieve a level of safety which is "at least equal to that i specification in the regulation from which the exemption is sought."
i In demonstrating an equivalent level of safety, in the case of very large objects not handled in l normal freight, the consignor may be able to show that the Type A packaging tests (particularly the free-drop) may not apply as a normal condition of transportation. Relative to applications for exemption from one or more of the regulatory packaging requirements, the l applicant must provide evidence of management control over the preparation, packaging arrangements, handling, and shipment to ensure conformance to the appropriate packaging requirements including r.ny special conditions imposed by DOT. An example of what might be provided as guidance follows. This considers the normal condition of transport drop test imposed ;
on various types of packages. The guidance being considered is:
i For very large objects, consideration may be given to seeking an exemption from
- the requirement to impose the normal condition of transport drop test on the L object in an unpackaged state. For objects with robust outer shells, such as steam generators, full closure of the structure may be provided using welded closures on l penetrations, and it may then be possible to demonstrate that the outer structure can effectively serve the function of a packaging.
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The outer shell would need to satisfy all of the requisite requirements for the required packaging, or arguments would need to be developed to preclude having to satisfy one or more of the requirements. Generally, such large robust structures can resist the normal conditions of transpon, except possibly the drop test. This drop test must be performed from a specified drop height and in a manner "so as to suffer maximum damage to the safety features being tested." These two factors, drop height and orientation, should be considered in developing a basis for an exemption.
Ralative to dron height of the obiect beine thinned unnarkagad the requirement was developed based upon the assumptions that, under normal conditions of transport, as the mass of the object increases, the required drop height decreases.
Specifically, the drop height requirements are bounded by:
(a) smaller packages [less than 5,000 kg (11,000 pounds)], wnere the required drop height is 1.2 m (4 S); whereas (b) for larger packages [ greater than 15,000 kg (33,000 pounds)],
where the required drop height is reduced to 0.3 m (1 A).
l The basis for this reduction in drop height with mass is discussed in Reference 9 l where it states:
I "Thefree bop test simulates the type ofshock that apackage
\ would experience ofit were tofall o[f the platform ofa vehicle or of it were hopped under handling. In most casespackages would continue thejourney after such shocks. Since heavierpackages are less likely to be exposed to large kop heights during normal handling, thefree bop distancefor this test is gradedaccording to package mass. Shoulda largepackage experience a sigmficant hop, this &op might be consideredan accident and the package wouldprobably not continue itsjourney without close examination."
i l Thus, it may be argued that the drop height which might be reasonable to consider for normal conditions oftranspon could be lower than 0.3 m (1 A) for very heavy objects. For example, if the object had a mass of 150,000 kg (330,000 pounds),
then a drop height of only 0.03 to 0.06 m (0.1 to 0.2 A) might be considered reasonable for an exemption. It may be possible to argue that it is highly unlikely to have a free drop by a qualified crane operator of such large objects under the
" normal conditions of transport." This would be especially true with one-of-a-kind shipment exemptions imposing rigidly controlled operational procedures for crane operators. Alternatively, the loading onto the conveyance may not be by crane 11 l
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whatsoever. Rather it may be jacked up sufficiently for the conveyance to be mcved underneath the object, and then be carefully and slowly lowered onto the conveyance. Also, for such large items, intermediate handling of them in transit is :
highly unlikely. With rigidly imposed handling controls, including the requirement !
to closely monitor all lifting activities, any free-release drop exceeding the height ;
specified in the exemption would be clearly identified. In the event such a drop l occurred, then this drop might be considered an accident, the cogmzant regulator ;
j would be notified, and the package would not be allowed to continue itsjourney l without close examination and remedial actions, followed by approval of the regulator (see preceding footnote).
R*lm*Ive to orientatinn of the obiect beine thinned unnmelemoed, a similar set of arguments can serve as the basis for exempting the requirement that the package withstand the drop height in the most damaging orientation.
It should be recognized that the requirement for performing the test in the most damaging orientation was imposed for smaller packages which could be dropped during handling, loading, in-transit transfers between vehicles, and unloading in a random fashion and could fall in almost any orientation. For very large objects, as described above, their lifting and lowering will generally be accomplished in a very ,
! well specified and well-controlled fashion, and a drop in the most damaging orientation can be administratively avoided. i l
The basis for the exemption application here could be that, because of such rigid controls, it is l highly unlikely the object would be released for a drop of any significant height in a most l damaging orientation. The orientation of the object for transport would need to be compared with the orientation required for greatest damage. In many cases, these orientations would be
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i sufficiently different from the proposed shipping orientation, such that when combined with (a) a justified lower drop height, (b) other steps which would be taken in preparing and transporting the object, and (c) any other safety control measures, then a level of safety would be achieved which is "at least equal to that specification in the regulation from which the exemption is l sought."
CONCLUSION In addition to the guidance discussed above, it is anticipated that several other issues related to the preparation, packaging and transport oflarge, contaminated or activated objects will be will l be clarified in the guidance, and those addressed above will be more fully elaborated upon.
In addition, as noted earlier, complementary guidance is being developed to address issues related to the application of the new regulatory requirements for general issues related to LSA material and SCOs. A companion paper on this effort is provided in this conference.
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This paper presents some of the U.S. regulatory staff's initial thoughts on issues relating to
! questions that have been asked on the revised regulations relative to large objects. Current plans are to issue joint guidance, in draft form, for public comment in 1997. Interested industry and members of the public will be encouraged to provide feedback, especially on the practicality of l what is presented. This feedback should include insights into additional "real world" problems, questions, examples, and experiences in implementing the revised regulations. These efforts, l when completed, should provide an opportunity for collaboration with personnel from other countries and the IAEA to develop guidance on these issues which can be accepted worldwide.
REFERENCES l
[l} Packaging and Transportation ofRadioactive Materials, Title 10 of the U.S. Code of Federal Regulations, Part 71, Nuclear Regulatory Commission, (as effective, April 1, 1996); U.S. Nuclear Regulatory Commission, Compatibility With the International Atomic Energy Agency (IAEA); Notice ofFinalRulemaking, 60 FR 50248; Washington, DC, USA,28 September 1995.
(2] Shippers - GeneralRequirementsfor Shipments andPackagings, Title 49 of the U.S.
Code of Federal Regulations, Part 173, Department of Transportation, (as effective, April 1,1996); and U.S. Department of Transportation, HazardousMaterials Transportation Regulations: Compatibility with Regulations of the International Atomic Energy Agency; Notice ofFinal Rule Making, 60 FR 50292; Washington, DC, US A, 28 i September 1995.
(3} Regulationsfor the Safe Transport ofRadioactive Material,1985 Edition (As amended 1990), Safety Series No.6, International Atomic Energy Agency, Vienna, Austria,1990.
[4] Development of guidance on applications of regulatory requirements for low specific activity materials and surface contaminated objects, R. B. Pope, E. P. Easton, S. F.
Sanchman, and R. W. Boyle, paper to be presented at the 4th International Conference on Transportation for the Nuclear Industry, Bournemouth, England, UK,13-15 May 1997.
(5} 1. M. Taylor, ProposedNuclear Regulatory Commission Generic Letter Entitled
" Interim Guidance on Transportation ofSteam Generators, Policyissue (Information),
SECY-96-239, Nuclear Regulatory Commission, Washington, DC November 19,1996.
[6] AdvisoryMaterialfor the IAEA Regulationsfor the Safe Transport ofRadioactive l Material,1985 Edition, ThirdEdition (As amended 1990), Safety Series No.37, j International Atomic Energy Agency, Vienna, Austria,1990.
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(7} M. C. Witte and C. K. Chou, A StructuralEvaluation of the Shippingport Reactor Pressure Vesselfor TransportImpact Conditions, Advances in Packaging and Transportation ofRadioactive Materials, PVP - Vol. 164, The American Society of Mechanical Engineers, New York, New York,1989.
[8] M. B. Lackey and M. L. Kelly, The Trojan Large Component RemovalProject, pp 11-17, RADWASTEMagazine, The American Nuclear Society, La Grange Park, Illinois, January,1997.
[9] ExplanatoryMaterialfor the IAEA Regulationsfor the Safe Transport ofRadioactive Material,1985 Edition, SecondEdition (As amended 1990), Safety Series No.7, International Atomic Energy Agency, Vienna, Austria,1990.
ACKNOWLEDGMENTS Acknowledgment is made of the contribution to the technical content of this paper by a number ofindividuals at the U.S. Nuclear Regulatory Commission (R. Lewis S. Sanchman), the Oak Ridge National Laboratory (S. Ludwig, R. Michelhaugh, and L. Shappert), and its subcontractors (R. Best and S. Schmid of Science Applications International Corporation, and J.
Goss and S. Schurman of H&R Technical Associates, Inc.).
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