Information Notice 1990-35, Transportation of Type a Quantities of Non-Fissile Radioactive Materials
| ML031210513 | |
| Person / Time | |
|---|---|
| Issue date: | 05/24/1990 |
| From: | Teneyck E 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