Information Notice 1990-35, Transportation of Type a Quantities of Non-Fissile Radioactive Materials

Transportation of Type a Quantities of Non-Fissile Radioactive Materials

ML031210513
Person / Time
Issue date:	05/24/1990
From:	TenEyck E Q Office of Nuclear Material Safety and Safeguards
To:
References
IN-90-035, NUDOCS 9005170283
Download: ML031210513 (10)

UNITED STATES NUCLEAR REGULATORY

COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 May 24, 1990 NRC INFORMATION

NOTICE NO. 90-35: TRANSPORTATION

OF TYPE A QUANTITIES

OF NON-FISSILE

RADIOACTIVE

MATERIALS

Addressees

All U.S. Nuclear Regulatory

Commission (NRC) Licensees.

Purpose

This notice is provided to summarize

and clarify the basic requirements

of the U.S. Department

of Transportation (DOT) Hazardous

Materials

Regulations (HMR)that are most frequently

cited as deficiencies

or violations

during inspections

of transportation

activities

of NRC licensees.

Such deficiencies

are most com-monly noted during inspections

of byproduct

materials

licensees, particularly

when such licensees

are first-time

users of the regulations

or those who package and deliver such packages to carriers only occasionally.

However, the infor-mation here should be useful to any type of licensee who prepares and delivers radioactive

material packages to carriers or transports

packages in his own vehicle as a private carrier.It is expected that addressees

will review the information

here for appli-cability to their licensed activities

and consider actions, as appropriate, to avoid problems in transport

of such materials.

However, suggestions

contained

in this notice do not constitute

any new requirements, and no written response is required.Background:

In 1979, NRC incorporated

into its own regulations

(10 CFR Part 71) the DOT regulations

contained

in 49 CFR Parts 170 to 178. (See 10 CFR 71.5.)This notice is an update of NRC IE Information

Notice No. 82-47 (Ref. 1), bearing the same title, issued November 30, 1982, and a series of three articles which appeared in NRC NMSS Licensee Newletter, during 1989.(Refs. 2, 3, 4.)Discussion:

Special Form vs. Normal Form Determination

For transportation

purposes, radioactive

materials

are classified

either as'special form" or "normal form," as defined in 49 CFR 173.403(s)

and (z).Radioactive

materials

classified

as "special form," such as sealed sources, 9012 9005170283

/f '1 IN 90-35 May 24, 1990 may be transported

with fewer restrictions

than other materials

with equal radioactivity.

However, sealed sources must meet the physical integrity requirements

defined in 49 CFR 173.469. All other radioactive

materials are considered

'normal form." For a particular

shipping package specification, the activity limits for special form material usually are greater than those for normal form materials

(49 CFR 173.435).

That is, if the material is in special form, a greater quantity of material usually is permitted

in the package.Any licensee who ships or transports

special form material, and declares it as such on shipping papers and package marking, must maintain documentation

containing

the results of the testing performed

on the material or source, to demonstrate

that it meets the special form requirements

[49 CFR 173.476(a)].

This does not mean that each shipper or transporter

must perform the tests, but that each must obtain and retain the test documentation.

Each licensee should establish

a file of such data for each special form design in its possession.

It is usually necessary

for the licensee to obtain this infor-mation from the source or device manufacturer.

Type A vs. Type B Package Determination

Normal form materials

in quantities

no greater than applicable

A limits (curies), specified

in 49 CFR 173.435, may be shipped in a packaie called a "Type Am package (i.e., one which is expected to maintain its integrity only during normal conditions

of transport).

Similarly, special form materials

may be shipped in larger quantities

up to the A limit, in a Type A package. Shipment of materials

in a single package in excess of these limits requires the use of the higher quality "Type B" package.(i.e., one which is expected to maintain its integrity

during both normal and severe accident conditions

of transport).

Examples of AI and A2 limits (in curies) from 49 CFR 173.435 are as follows: Radionuclide

A,(special

form) A,(normal

form)Am-141 20 0.008 (in AmBe sources)Co-60 7 7 Cs-137 30 10 Ir-192 20 10 Mo-99 100 20

IN 90-35 May 24, 1990 In some instances, qualification

of the material as *special form" will have no bearing on the type of packaging

required, relative to the activity of the material shipped. For example, in the case of shipment of less than seven curies of Co-60, Type A (rather than Type B) packaging

may be used regardless

of form (normal or special), because the Type A package limit prescribed

in 49 CFR 173.435 is seven curies for both special form (the A limit) and normal form (the A limit). This contrasts

with CS-137, where any quantity exceeding

10 curiei (the A limit) in normal form requires Type B packaging, and as much as 30 curies ({he Al limit in special form) are allowed in Type A packaging.

In any situation

where the material is described

on shipping papers and package marking as "Radioactive

material, special form, n.o.s." (n.o.s.means *not otherwise

specified"), the shipper is required to maintain the special form documentation

prescribed

by 49 CFR 173.476(a).

To avoid this requirement, the shipper may elect to describe the material as "Radioactive

material, n.o.s.w However, this description

may only be used if the special form material in the Type A package does not exceed the normal form limit (the A2 limit).DOT Specification

7A, Type A Packages As indicated

previously, normal form materials

can be shipped in a "Type A" package, as long as the contained

quantity does not exceed the A limits (in curies) specified

in 49 CFR 173.435. Similarly, special forW materials that do not exceed the A1 limits (which, for certain materials, may be higher than the A 2 limits) also may be shipped in a Type A package.The usual Type A package specification

is referred to as "DOT Specification

7A" in 49 CFR 173.415(a).

This is a pure "performance" specification

and is not based on any specific and detailed design specifications.

For Speci-fication 7A, DOT regulations

require that each shipper of a Specification

7A package must maintain on file written documentation

attesting

to the results of the Specification

7A performance

tests performed

on the package design.Remember that a "shipper" also includes any NRC licensee transporting

licensed material in his own vehicle, (i.e., a "shipper" acting as a "private carrier").

If the shipper of a Specification

7A package is not the original designer or user of that package, it is necessary

for that shipper to obtain the test result data from the original supplier.

Alternately, the shipper may perform the tests and document the results. The tests are described in 49 CFR 173.465-466.

Type A packages also must meet the design require-ments described

in 49 CFR 173.411-412.

IN 90-35 May 24, 1990 If a shipper makes any changes, to the packaging

or its maximum authorized

contents, from those described

on the original test report furnished

by another person, the shipper must perform and document a supplemental

evaluation, addressing

such changes, demonstrating

that the package will continue to meet the appropriate

performance

requirements.(Reference

5, a U.S. Department

of Energy (DOE) evaluation

document for Type A packaging, is a useful document which may be of value to shippers in the preparation

of their DOT Specification

7A documentations.)

Labeling (Labels are for packages.)

Each package must be labeled with one of the three "RADIOACTIVE" labels described in 49 CFR 172.403. The three labels are referred to as RADIOACTIVE

WHITE-I, RADIOACTIVE

YELLOW-Il, and RADIOACTIVE

YELLOW-III.

RADIOACTIVE

WHITE-I is the lowest category label and RADIOACTIVE

YELLOW-III

is the highest. Labels must be affixed on each of two opposite sides of the package (49 CFR 172.406) and must measure 4 inches on each side (49 CFR 172.407).

DOT regulations

display the formats of these labels in 49 CFR 172.436-440.

All the labels include spaces for marking (1) the contents (the name of the radionuclide)

and (2) the activity (in curies, millicuries, or microcuries).

The YELLOW labels also include spaces for marking the Transport

Index (TI).The TI is a number expressing

the maximum radiation

level in millirem per hour at 1 meter (3.3 feet) from the external surface of the package.The appropriate

label is selected based on the measured radiation

levels anywhere on the external surface of the package and based on the package TI. A WHITE-I label may be used if the radiation

level at any point on the surface of the package does not exceed 0.5 mrem/hr. A YELLOW-II

label indicates

that the surface rate does not exceed 50 mrem/hr and the TI does not exceed 1. Higher radiation

levels require use of the YELLOW-III

label.Pursuant to 49 CFR 173.441, package radiation

levels are limited to 200 mrem/hr at the surface and 10 mrem/hr at 1 meter (i.e., a TI of 10).Placarding (Placards

are for vehicles.)

The outside of the transport

vehicle must be placarded

by the carrier on the front, rear, and each side with the RADIOACTIVE

placard (identified

in 49 CFR 172.556) only if any package in the vehicle bears the RADIOACTIVE

YELLOW-III

label. The licensee (shipper)

is required to furnish the placards to a common or contract carrier at the time the packages are delivered

to, (i.e., picked up by) that carrier. In the case of a licensee acting as a shipper/private

carrier, obviously, the licensee must apply the placards.

Vehicles are not required to be placarded

when the shipment includes only WHITE-I or YELLOW-II packages.

[Note: In the case of exclusive-use

shipments

of low specific activity (LSA) materials, the shipper must placard the vehicle, even though such LSA packages are exceptedfr-o-mlabeling.]

IN 90-35 May 24, 1990 DOT placard requirements

should not be confused with the posting requirements

of 10 CFR 20.203. Any temporary

storage on a loading dock or transport

vehicle at a licensee's

facility must also comply with the applicable

requirements

of 10 CFR Part 20, as well as with other appropriate

NRC regulations.

Labels and placards should be procured commercially.

They are not obtainable

from NRC.Package Marking The outside of each package must be marked with the following:

1. Applicable

DOT Proper Shipping Name (see 49 CFR 172.101 List of Hazardous Materials);

and "RQ,w if a *reportable

quantity" is present (see 49 CFR 172.101, Appendix Table 2, for radionuclide

reportable

quantities);

2. Identification

Number (49 CFR 172.101);3. Applicable

DOT Specification, (e.g., "DOT-7A," "Type A");4. Gross Weight [for packages in excess of 110 lbs (50 kilograms)];

5. The Marking "USA," if the package is destined for export;6. The name and address of the consignee

or consignor. (Both are recommended.)

Shipping Papers A shipping paper is required for each transport

of radioactive

material from the confines of the licensee's

facility, whether transported

by the licensee in his own vehicles or delivered

to a common carrier for transport.

A properly certified

shipping paper is an indicator

of compliance

with DOT regulations

and is of prime importance

to authorities

in case of an accident, loss, or theft.It must include the information

required by 49 CFR 172.202-203, including

the following:

1. The applicable

DOT proper shipping name from 49 CFR 172.101. (For sources that are shipped as special form, this will always be uRadio-active material, special form, n.o.s." For normal form materials, the shipping name will generally

be "Radioactive

material, n.o.s.")2. The applicable

Identification

Number from 49 CFR 172.101. (For materials shipped as "Radioactive

material special form, n.o.s.," this number is UN2974. For materials

shipped as "Radioactive

material, n.o.s.," this number is UN2982.)3. For a radionuclide

as a "hazardous

substance'

in a quantity exceeding

the applicable "reportable

quantity," the entry "RQ" shall immediately

precede or follow the entries in 1 and 2, above.

--IN 90-35 May 24, 1990 4. The name of each radionuclide. (For example, "Co-60.")5. A description

of the physical and chemical form of the material. (For special form sources, this description

is "SPECIAL FORM.")6. The activity contained

in each package, measured in curie units.7. The category of label applied to each package ("RADIOACTIVE

WHITE-I,""RADIOACTIVE

YELLOW-II," OR "RADIOACTIVE

YELLOW-III").

8. The transport

index (radiation

level at 1 meter) assigned to each package bearing YELLOW-II

or YELLOW-IlI

labels. (For packages destined for carriage on passenger-carrying

aircraft, the maximum TI is 3 rather than 10.)9. For shipments

tendered to a common carrier, the appropriate

signed shipper's

certification

(49 CFR 172.204).

For shipments

by aircraft, the additional

statement

as to acceptability

for either passenger- carrying or cargo-only

aircraft.

For shipments

by passenger-carrying

aircraft, the additional

statement

of intended use in research, medical diagnosis, or treatment

must also be included.10. An emergency

response telephone

number, for use in the event of an emergency

involving

the package.When licensees

transport

sealed source packages in their own vehicles repetitively, a reusable type of shipping paper documentation

may be used that is specific to each particular

package configuration.

Such documentation

can take the form of laminated

cards retained in the cab of the vehicle, thereby eliminating

the need for preparing

a new shipping paper document every time a shipment is made.Shipping papers must be maintained

in the vehicle, within the immediate

reach of the driver restrained

by the lap belt. Ordinarily, a glove compartment

does not meet this requirement.

[49 CFR 177.817(e)

provides detailed infor-mation on accessibility

of shipping papers within vehicles.]

Blocking, Bracing, and Securing of Packages Licensees

who transport

packages in their own vehicles must provide for adequate blocking, bracing, or tie-down of the packages to prevent shifting or movement during normal transport.

Licensees

also are required to provide security measures adequate to prevent the unauthorized

removal of materials from the place of storage during transport, pursuant to 10 CFR 20.207. This may involve locking the packages within an external, permanently-attached

compartment

of the vehicle, or within the cargo compartment, itself. In either case, it is necessary

to remove the keys from the vehicle. (See Reference

6, Information

Notice No. 87-31, for further information

on blocking, bracing and securing of packages during transport.)

IN 90-35 May 24, 1990 A Caution -Obtain a Copy of the Regulations

I This notice is for information

and guidance.

Reference

7, a review of DOT regulations

on radioactive

material transport, may also be useful to readers of this notice. Neither source should be considered

as a substitute

for the actual copy of the regulations.

All licensees

who package or transport

radio-active packages are urged to avail themselves

of up-to-date

copies of the ap-plicable NRC and DOT regulations.

Copies of these regulations (i.e., Title 49 of the Code of Federal Regulations)

can be obtained from Superintendent

of Documents, U.S. Government

Printing Office, Washington, D.C. 20402-9371

(202) 783-3238.Future Regulatory

Revision This notice is based on the DOT and NRC regulations

in effect at the time of issuance of this notice. Readers are advised that both NRC and DOT are cur-rently in the midst of rulemaking

actions to effect revisions

to the regulations

of the U.S. so as to incorporate

the latest standards

of the International

Atomic Energy Agency in the 1985 edition (as supplemented)

of its Safety Series No. 6, "Regulations

for the Safe Transport

of Radioactive

Materials." (Ref. 8) The Notices of Proposed Rulemaking

by each agency are listed in References

9 and 10. It is estimated

that final action on the regulatory

requirements

will be taken in late 1990 or early 1991.Eli eth Q. n Eyck, Acing Director Di sion of Safeguards

and Transportation

Office of Nuclear Material Safety and Safeguards

Technical

Contacts:

A. W. Grella, NMSS (301) 492-3381 C. L. Cain, USNRC, Region IV (817) 860-8186 Attachments:

1. References

2. List of Recently Issued NMSS Information

Notices 3. List of Recently Issued NRC Information

Notices

Attachment

1 IN 90-35 May 24, 1990 REFERENCES

1. U.S. Nuclear Regulatory

Commission, IE Information

Notice No. 82-47,"Transportation

of Type A Quantities

of Non-Fissile

Radioactive

Materials." 2. U.S. Nuclear Regulatory

Commission, NMSS Licensee Newsletter, Office of Nuclear Materials

Safety and Safeguards, NUREG/BR-0117, No. 89-1, March 1989.3. Ibid, No. 89-2, June 1989.4. Ibid, No. 89-3, September

1989.5. D. A. Edling et al., *DOE Evaluation

Document for DOT 7A Type A Packaging," MLM-3245 (DOE7DV70O53-H1), March 1987.6. NRC Information

Notice No. 87-31, "Blocking, Bracing, and Securing of Radioactive

Materials

Packages In Transportation," July 10, 1987.7. U.S. Department

of Transportation, "A Review of the Department

of Transportation

Regulations

for Transportation

of Radioactive

Materials," revised 1983. Available

from U.S. Department

of Transportation, Research and Special Programs Administration, Washington, DC (202-366-2301)

or U.S. Government

Printing Office.8. International

Atomic Energy Agency, "Regulations

for the Safe Transport of Radioactive

Material, Safety Series No. 6, 1985 Edition," as sup-plemented.

Available

in the U.S. from: BERNAN-UNIPUB, 4611-F Assembly Drive, Lanham, Maryland 20706-4341.

9. U.S. Nuclear Regulatory

Commission, "Transportation

Regulations:

Compatibility

with the International

Atomic Energy Agency," Federal Register, Vol. 53, No. 110, June 8, 1988. (Proposed Rule, 10 CF Part 71.)10. U.S. Department

of Transportation, Research and Special Programs Administration, "Transportation

Regulations:

Compatibility

with Regulations

of the International

Atomic Energy Agency: Notice of Proposed Rule," (49 CFR Part 171, et al.), Federal Register, Vol. 54, No. 218 (Part II), November 14, 1989.

Attachment

2 IN 90-35 May 24, 1990 LIST OF RECENTLY ISSUED NMSS INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to: 90-27 Clarification

of the Recent Revisions

to the Regulatory

Requirements

for Packaging

of Uranium Hexafluoride (UF 6) for Transportation

04/30/90 All Uranium Fuel Fabrication

and Conversion

Facilities

90-24 90-20 90-16 Transportation

of Model SPEC 2-T Radiographic

Exposure Device Personnel

Injuries Resulting

from Improper Operation

of Radwaste Incinerators

Compliance

with New Decommissioning

Rule Reciprocity:

Notification

of Agreement

State Radiation Control Directors

before Beginning

Work in Agreement States Accidental

Disposal of Radioactive

Materials Extended Interim Storage of Low-Level

Radioactive

Waste by Fuel Cycle and Materials Licensees 04/10/90 03/22/90 03/07/90 03/07/90 03/06/90 02/05/90 All NRC licensees authorized

to use, transport, or operate radiographic

exposure devices and source changers All U.S. NRC licensees who process or incinerate

radioactive

waste All materials

licensees All holders of NRC materials

licenses that authorize

use of radio-active material at temporary

job sites All NRC byproduct materials

licensees All holders of NRC materials

licenses 90-15 90-14 90-09 Correct Number for IN 90-01 should be 9001080145.

Attachment

3 IN 90-35 May 24, 1990 LIST OF RECENTLY ISSUED NRC INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to 90-34 Response to Activations

False Siren 5/10/90 All holders of OLs or CPs for nuclear power reactors.90-33 90-32 90-31 90-30 90-29 90-28 90-27 Sources of Unexpected

Occupational

Radiation Exposures

at Spent Fuel Pools Surface Crack and Subsurface

Indications

in the Weld of A Reactor Vessel Head Update on Waste Form and High Integrity

Container Topical Report Review Status, Identification

of Problems with Cement Solidification, and Reporting

of Waste Mishaps Ultrasonic

Inspection

Techniques

for Dissimilar

Metal Welds Cracking of Cladding and Its Heat-Affected

Zone in the Base Metal of a Reactor Vessel Head Potential

Error in High Steamline

Flow Setpoint Clarification

of the Recent Revisions

to the Regulatory

Requirements

for Packaging

of Uranium Hexafluoride (UF 6) for Transportation

5/9/90 5/3/90 5/4/90 5/1/90 4/30/90 4/30/90 4/30/90 All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors, fuel cycle licenses, and certain by-product

materials

licenses.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for BWRs.All uranium fuel fabrication

and conversion

facilities.

OL = Operating

License CP = Construction

Permit