ML22066A374
| ML22066A374 | |
| Person / Time | |
|---|---|
| Issue date: | 03/04/2022 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Beardsley M | |
| Shared Package | |
| ML22066A027 | List: |
| References | |
| Download: ML22066A374 (5) | |
Text
2021 Rationale for Part T 2021 RATIONALE FOR REVISIONS PART T TRANSPORTATION OF RADIOACTIVE MATERIAL Introduction Persons who transport radioactive material or deliver radioactive material to a carrier for transport are subject to the requirements for packaging, preparation for shipment and care during shipments.
These requirements are found in this Part T of the Suggested State Regulations for Control of Radiation (SSRCR) of the Conference of Radiation Control Program Directors (CRCPD). Since 1988 the requirements for transportation have been located separate from Part C (Licensing of Radioactive Material) in this Part T.
This 2015 revision of Part T incorporates changes adopted by the U.S. Department of Transportation (DOT) and U.S. Nuclear Regulatory Commission (NRC) in response to recommendations by the International Atomic Energy Agency (IAEA) in their Transportation Safety Standards TS-R-1 and NRC-initiated changes. These revisions made United States regulations compatible with the domestic regulations of most of the international community by bringing United States regulations into accord with relevant portions of the IAEA design and performance requirements to the extent considered feasible. The DOT revisions to Title 49 of the Code of Federal Regulations (CFR) Part 171 begin at 79 Federal Register (FR) 40590. The NRC changes to 10 CFR Part 71 begin at 80 FR 33987 (to 34018; 32 pages).
The NRC considers the adoption of a regulation equivalent to 10 CFR Part 71 a matter of compatibility for an Agreement State. The various provisions of the 10 CFR Part 71 regulation are assigned different compatibility and health and safety categories. Definitions of each category and the specific category assigned to each provision of 10 CFR Part 71 are set out in NRC, Office of Federal and State Materials and Environmental Management Programs (FSME) Procedure SA-200, Compatibility Categories and Health and Safety Identification for NRC Regulations and Other Program Elements.
Changes in the federal regulations to achieve compatibility with IAEA regulations include adoption of radionuclide exemption values in TS-R-1 to assure continued consistency between domestic and international regulations for the basic definition of radioactive material. Minor changes to the A1 and A2 values were adopted, in order to retain consistency between domestic and international regulations for radioactive material.
Traditionally, the DOT has used a specific activity threshold (70 Bq/g (0.002uCi/g)) for defining a material as radioactive for transportation purposes. During the development of TS-R-1, it was recognized that there is no technical justification for the use of a single activity-based exemption value for all radionuclides. A more rigorous technical approach would be to base radionuclide exemptions on a uniform dose basis, rather than a uniform specific activity. Thus, in accordance with the NRC and DOT adopting this new approach in the previous version, Table A-2 established 2021 Rationale for Part T the exempt material activity concentrations and exempt consignment activity limits for radionuclides. Table A-2 was slightly revised in this revision.
The maximum activity of radioactive material that is permitted to be transported in a Type A package is known as the A1 and A2 values in Table A-1. The A1 values apply to special form radioactive material, and the A2 values apply to normal form radioactive material. These values apply as a package content limit. In addition, fractions of these values can be used for a limited quantity of solid radioactive material or multiples of these values to establish a highway route controlled quantity threshold value.
Many years ago the IAEA adopted new A1 and A2 values for radionuclides listed in TS-R-1. These new values were based on calculations which were performed using the latest dosimetric models recommended by the International Commission on Radiation Protection (ICRP) in Publication 60, 1990 Recommendations of the ICRP. Incorporation of data from updated metabolic uptake studies were also included. In addition, several refinements were introduced in the calculation of contributions to the effective dose from each of the pathways considered, i.e., external photon dose, external beta dose, inhalation dose, skin and ingestion dose from contamination, and dose from submersion in gaseous radionuclides. Though a thorough, up-to-date assessment was performed for each radionuclide, the reference doses, which are used to define an acceptable dose in the event of an accident, were unchanged. As an example, if either the A1 or A2 value is increased, then the use of the revised dosimetric models just shows that a higher activity of that radionuclide is actually required to produce the same reference dose.
Because the IAEA will be changing its recommended A1 value for californium-252 back to the previous value in 10 CFR 71 and 49 CFR, the NRC and DOT will change this value for californium-252.
Currently, the domestic A2 value for molybdenum-99 is 0.74TBq (20 Ci). The IAEA proposed value is 0.6 TBq (16.2 Ci). Because this lower value will cause a significant increase in the number of shipments and a corresponding increase in the occupational doses to individuals, both NRC and DOT are retaining the current value for this radionuclide.
Also, the NRC and DOT will not be including the A1 and A2 values for 16 radionuclides not included in TS-R-1. This will allow for continued consistency between the international and domestic transportation regulations for radioactive material.
Historically, the transport index (TI) has been used to determine the appropriate safety requirements during transport. It has been used to control the accumulation of packages for both radiological safety and criticality safety purposes and to specify minimum separation distances from persons.
The TI has been a single number, which is the larger of two values: the TI for criticality control purposes and the TI for radiation control purposes. Using the larger of the two has ensured conservatism in limiting the accumulation of packages. The TS-R-1 has introduced a new term, i.e.,
criticality safety index, which is determined in the same way as the TI for criticality control purposes.
Specific Provisions 2021 Rationale for Part T Sec. T.1 - Purpose and Scope. The Purpose and Scope was changed to update the paragraph references in T.1.d. However, all wording within 10 CFR 71s Purpose and Scope were not incorporated because they are captured by other sections in this Part. The Purpose and Scope also incorporated changes to comply with the format prescribed by the CRCPDs SSRCR Style Manual.
Sec. T.2 - Definitions. Minor changes were made throughout to comply with the format prescribed by the SSRCR Style Manual and to correct references. Other definitions were added and/or revised to be compatible with the definitions listed in 10 CFR 71.
The following definitions were revised in Part T:
- a. "Contamination "
- b. "Criticality Safety Index"
- c. "Low Specific Activity (LSA)"
- d. "Special form radioactive material"
- e. "Uranium natural, depleted, enriched" These definitions were revised to maintain consistency with IAEAs TS-R-1. All other definitions in Section T.2 remain unchanged.
Definitions listed in 10CRF71 as Compatibility Level D (in RATS 2015-3) were not included in SR-T.
Sec. T.3 - Requirement for License. There were no changes recommended for this section.
Sec. T.4 - Exemptions. There was no change to paragraph "a". Revisions in 10 CFR 71.10(a),
which becomes 10 CFR 71.14(a), are incorporated into paragraph "b". This change removed the existing single specific activity value and replaced it with "Activity Concentration for Exempt Material" found in Table A-2. The balance of the paragraph was formatted in conformance to 10 CFR 71.14(a).
New paragraphs "c" and "d" were created to incorporate 10 CFR 71 changes which cover exemptions from classifications as fissile material.
Sec. T.5 - Transportation of Licensed Material. This section remains unchanged, except for adding
§§ 172.441 which specifies requirements for labeling fissile packages and updating the SSR reference from D.906.e to D.1906e.
It should be noted that in 49 CFR 173.403 the definition of "exclusive use" was changed to require appropriate radiological training and resources by the consignor and carrier to ensure safe handling of the consignment.
Sec. T.6 - General Licenses for Carriers. There was no change to this section.
2021 Rationale for Part T Sec. T.7 - General License: Nuclear Regulatory Commission-Approved Packages. This section is revised to remove the brackets on the Compatibility Category ([B] to B) and to modify NRC/Commission information to appropriate Agreement State Agency information.
Sec. T.8 - General License: Use of Foreign Approved Package. This section is revised to remove the brackets on the Compatibility Category ([B] to B) and to modify NRC/Commission information to appropriate Agreement State Agency information.
Sec. T.9 - Sec T.12 - No changes to these sections.
Sec. T.13 - Preliminary Determinations. Added new paragraph (d) to ensure determinations in paragraphs (a) through (c) have been made. Paragraphs (a) through (c) of this section refers to 71.85(a) through (c), which are assigned Compatibility Category NRC and cant be adopted by the Agreement States. Consequently, in 71.85(d), Agreement States should reference 10 CFR 71.85(a) through (c) and not their own regulations.
Sec. T.14 - T.16 - No changes to these sections.
Sec. T.17 Shipment Records. Change Compatibility from D to C for paragraphs (a), (b), and (c). Changed reference in paragraph (a).
Removal of phrase certificate holder, and applicant for a CoC since NRC has sole authority for issuing a Certificate of Compliance Modify NRC/Commission information to appropriate Agreement State Agency information.
Sec. T.18 - Reports. Section remains unchanged.
Sec. T.19 - Advance Notification of Shipment of Nuclear Waste. Reworded to be consistent with 10 CFR 71.97.
Sec. T.20 - Quality Assurance Requirements.
Change Compatibility to C for paragraphs (a), (e), and (f).
Removal of phrase certificate holder, and applicant for a CoC from paragraphs b, c, and e since NRC has sole authority for issuing a Certificate of Compliance.
Modify NRC/Commission information to also include appropriate Agreement State Agency information in paragraphs b, c, l, and m.
Sec. T.21 - Quality Assurance Records Change Compatibility to only C Removal of phrase certificate holder, and applicant for a CoC since NRC has sole authority for issuing a Certificate of Compliance.
2021 Rationale for Part T Appendix A was revised as follows:
Paragraphs IV.a and IV.b were revised to correct formulas.
Redesignated paragraphs IV.c through IV.f to IV.d through IV.g. and revise to correct.
Added new paragraph IV.c.
Redesignated paragraph V. as paragraph V.a and added new paragraph V.b.
In Table A-1 of Appendix A, added an entry for Kr-79 in alphanumeric order; revised the entries for Cf 252, Ir-192, Kr-81, Mo 99, and Sm-147; revised footnotes a and c; removed footnote h; and redesignated footnote i as footnote h.
In Table A-2 of Appendix A, added the entry for Kr-79 in alphanumeric order, revised the entries for Kr 81 and Te 121m, and revised footnote b.
In Table A-3 of Appendix A, revised the second and third entries and added a new footnote a.