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 Q Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| IN-90-035, NUDOCS 9005170283 | |
| Download: ML031210513 (10) | |
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDSWASHINGTON, D.C. 20555May 24, 1990NRC INFORMATION NOTICE NO. 90-35: TRANSPORTATION OF TYPE A QUANTITIES OFNON-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 theU.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR)that are most frequently cited as deficiencies or violations during inspectionsof transportation activities of NRC licensees. Such deficiencies are most com-monly noted during inspections of byproduct materials licensees, particularlywhen such licensees are first-time users of the regulations or those who packageand deliver such packages to carriers only occasionally. However, the infor-mation here should be useful to any type of licensee who prepares and deliversradioactive material packages to carriers or transports packages in his ownvehicle 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, suggestionscontained in this notice do not constitute any new requirements, and nowritten response is required.Background:In 1979, NRC incorporated into its own regulations (10 CFR Part 71) the DOTregulations 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 threearticles which appeared in NRC NMSS Licensee Newletter, during 1989.(Refs. 2, 3, 4.)Discussion:Special Form vs. Normal Form DeterminationFor 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,90129005170283 /f '1 IN 90-35May 24, 1990 may be transported with fewer restrictions than other materials with equalradioactivity. However, sealed sources must meet the physical integrityrequirements defined in 49 CFR 173.469. All other radioactive materialsare considered 'normal form." For a particular shipping package specification,the activity limits for special form material usually are greater than thosefor normal form materials (49 CFR 173.435). That is, if the material is inspecial form, a greater quantity of material usually is permitted in thepackage.Any licensee who ships or transports special form material, and declares itas such on shipping papers and package marking, must maintain documentationcontaining 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 licenseeshould establish a file of such data for each special form design in itspossession. It is usually necessary for the licensee to obtain this infor-mation from the source or device manufacturer.Type A vs. Type B Package DeterminationNormal form materials in quantities no greater than applicable A limits(curies), specified in 49 CFR 173.435, may be shipped in a packaie calleda "Type Am package (i.e., one which is expected to maintain its integrityonly during normal conditions of transport). Similarly, special formmaterials may be shipped in larger quantities up to the A limit, in aType A package. Shipment of materials in a single package in excess ofthese limits requires the use of the higher quality "Type B" package.(i.e., one which is expected to maintain its integrity during both normaland 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 7Cs-137 30 10Ir-192 20 10Mo-99 100 20
IN 90-35May 24, 1990 In some instances, qualification of the material as *special form" will haveno bearing on the type of packaging required, relative to the activity of thematerial shipped. For example, in the case of shipment of less than sevencuries of Co-60, Type A (rather than Type B) packaging may be used regardlessof form (normal or special), because the Type A package limit prescribed in49 CFR 173.435 is seven curies for both special form (the A limit) andnormal form (the A limit). This contrasts with CS-137, where any quantityexceeding 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 Apackaging.In any situation where the material is described on shipping papers andpackage marking as "Radioactive material, special form, n.o.s." (n.o.s.means *not otherwise specified"), the shipper is required to maintain thespecial form documentation prescribed by 49 CFR 173.476(a). To avoid thisrequirement, the shipper may elect to describe the material as "Radioactivematerial, n.o.s.w However, this description may only be used if the specialform material in the Type A package does not exceed the normal form limit(the A2 limit).DOT Specification 7A, Type A PackagesAs 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 materialsthat do not exceed the A1 limits (which, for certain materials, may be higherthan the A2 limits) also may be shipped in a Type A package.The usual Type A package specification is referred to as "DOT Specification7A" in 49 CFR 173.415(a). This is a pure "performance" specification andis not based on any specific and detailed design specifications. For Speci-fication 7A, DOT regulations require that each shipper of a Specification 7Apackage must maintain on file written documentation attesting to the resultsof the Specification 7A performance tests performed on the package design.Remember that a "shipper" also includes any NRC licensee transporting licensedmaterial 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 designeror user of that package, it is necessary for that shipper to obtain thetest result data from the original supplier. Alternately, the shippermay perform the tests and document the results. The tests are describedin 49 CFR 173.465-466. Type A packages also must meet the design require-ments described in 49 CFR 173.411-412.
IN 90-35May 24, 1990 If a shipper makes any changes, to the packaging or its maximum authorizedcontents, from those described on the original test report furnished byanother person, the shipper must perform and document a supplementalevaluation, addressing such changes, demonstrating that the packagewill continue to meet the appropriate performance requirements.(Reference 5, a U.S. Department of Energy (DOE) evaluation document forType A packaging, is a useful document which may be of value to shippersin 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 describedin 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 thelowest category label and RADIOACTIVE YELLOW-III is the highest. Labels mustbe affixed on each of two opposite sides of the package (49 CFR 172.406) andmust measure 4 inches on each side (49 CFR 172.407). DOT regulations displaythe formats of these labels in 49 CFR 172.436-440.All the labels include spaces for marking (1) the contents (the name of theradionuclide) 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 perhour at 1 meter (3.3 feet) from the external surface of the package.The appropriate label is selected based on the measured radiation levelsanywhere on the external surface of the package and based on the packageTI. A WHITE-I label may be used if the radiation level at any point onthe surface of the package does not exceed 0.5 mrem/hr. A YELLOW-II labelindicates that the surface rate does not exceed 50 mrem/hr and the TI doesnot exceed 1. Higher radiation levels require use of the YELLOW-III label.Pursuant to 49 CFR 173.441, package radiation levels are limited to 200mrem/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 thefront, rear, and each side with the RADIOACTIVE placard (identified in 49 CFR172.556) only if any package in the vehicle bears the RADIOACTIVE YELLOW-IIIlabel. The licensee (shipper) is required to furnish the placards to a commonor contract carrier at the time the packages are delivered to, (i.e., pickedup by) that carrier. In the case of a licensee acting as a shipper/privatecarrier, obviously, the licensee must apply the placards. Vehicles are notrequired to be placarded when the shipment includes only WHITE-I or YELLOW-IIpackages. [Note: In the case of exclusive-use shipments of low specificactivity (LSA) materials, the shipper must placard the vehicle, even thoughsuch LSA packages are exceptedfr-o-mlabeling.]
IN 90-35May 24, 1990 DOT placard requirements should not be confused with the posting requirementsof 10 CFR 20.203. Any temporary storage on a loading dock or transport vehicleat a licensee's facility must also comply with the applicable requirements of10 CFR Part 20, as well as with other appropriate NRC regulations.Labels and placards should be procured commercially. They are not obtainablefrom NRC.Package MarkingThe outside of each package must be marked with the following:1. Applicable DOT Proper Shipping Name (see 49 CFR 172.101 List of HazardousMaterials); and "RQ,w if a *reportable quantity" is present (see 49 CFR172.101, 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 PapersA shipping paper is required for each transport of radioactive material fromthe confines of the licensee's facility, whether transported by the licenseein his own vehicles or delivered to a common carrier for transport. A properlycertified shipping paper is an indicator of compliance with DOT regulations andis 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 thefollowing:1. The applicable DOT proper shipping name from 49 CFR 172.101. (Forsources 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 materialsshipped as "Radioactive material special form, n.o.s.," this number isUN2974. For materials shipped as "Radioactive material, n.o.s.," thisnumber is UN2982.)3. For a radionuclide as a "hazardous substance' in a quantity exceeding theapplicable "reportable quantity," the entry "RQ" shall immediately precedeor follow the entries in 1 and 2, above.
--IN 90-35May 24, 1990 . The name of each radionuclide. (For example, "Co-60.")5. A description of the physical and chemical form of the material. (Forspecial 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 eachpackage bearing YELLOW-II or YELLOW-IlI labels. (For packagesdestined for carriage on passenger-carrying aircraft, the maximumTI is 3 rather than 10.)9. For shipments tendered to a common carrier, the appropriate signedshipper'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-carryingaircraft, the additional statement of intended use in research, medicaldiagnosis, or treatment must also be included.10. An emergency response telephone number, for use in the event of anemergency 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 specificto each particular package configuration. Such documentation can take theform of laminated cards retained in the cab of the vehicle, thereby eliminatingthe need for preparing a new shipping paper document every time a shipment ismade.Shipping papers must be maintained in the vehicle, within the immediate reachof the driver restrained by the lap belt. Ordinarily, a glove compartmentdoes 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 PackagesLicensees who transport packages in their own vehicles must provide foradequate blocking, bracing, or tie-down of the packages to prevent shiftingor movement during normal transport. Licensees also are required to providesecurity measures adequate to prevent the unauthorized removal of materialsfrom the place of storage during transport, pursuant to 10 CFR 20.207. Thismay involve locking the packages within an external, permanently-attachedcompartment of the vehicle, or within the cargo compartment, itself. Ineither case, it is necessary to remove the keys from the vehicle. (SeeReference 6, Information Notice No. 87-31, for further information onblocking, bracing and securing of packages during transport.)
IN 90-35May 24, 1990 A Caution -Obtain a Copy of the Regulations IThis notice is for information and guidance. Reference 7, a review of DOTregulations on radioactive material transport, may also be useful to readersof this notice. Neither source should be considered as a substitute for theactual 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 49of the Code of Federal Regulations) can be obtained from Superintendent ofDocuments, U.S. Government Printing Office, Washington, D.C. 20402-9371(202) 783-3238.Future Regulatory RevisionThis notice is based on the DOT and NRC regulations in effect at the time ofissuance 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 regulationsof the U.S. so as to incorporate the latest standards of the InternationalAtomic Energy Agency in the 1985 edition (as supplemented) of its SafetySeries No. 6, "Regulations for the Safe Transport of Radioactive Materials."(Ref. 8) The Notices of Proposed Rulemaking by each agency are listed inReferences 9 and 10. It is estimated that final action on the regulatoryrequirements will be taken in late 1990 or early 1991.Eli eth Q. n Eyck, Acing DirectorDi sion of Safeguardsand TransportationOffice of Nuclear Material Safetyand SafeguardsTechnical Contacts: A. W. Grella, NMSS(301) 492-3381C. L. Cain, USNRC, Region IV(817) 860-8186Attachments:1. References2. List of Recently Issued NMSS Information Notices3. List of Recently Issued NRC Information Notices
Attachment 1IN 90-35May 24, 1990 REFERENCES1. U.S. Nuclear Regulatory Commission, IE Information Notice No. 82-47,"Transportation of Type A Quantities of Non-Fissile RadioactiveMaterials."2. U.S. Nuclear Regulatory Commission, NMSS Licensee Newsletter, Officeof 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 ofRadioactive Materials Packages In Transportation," July 10, 1987.7. U.S. Department of Transportation, "A Review of the Department ofTransportation 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 Transportof Radioactive Material, Safety Series No. 6, 1985 Edition," as sup-plemented. Available in the U.S. from: BERNAN-UNIPUB, 4611-F AssemblyDrive, 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. (ProposedRule, 10 CF Part 71.)10. U.S. Department of Transportation, Research and Special ProgramsAdministration, "Transportation Regulations: Compatibility withRegulations of the International Atomic Energy Agency: Notice ofProposed Rule," (49 CFR Part 171, et al.), Federal Register,Vol. 54, No. 218 (Part II), November 14, 1989.
Attachment 2IN 90-35May 24, 1990 LIST OF RECENTLY ISSUEDNMSS INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to:90-27Clarification of theRecent Revisions to theRegulatory Requirementsfor Packaging of UraniumHexafluoride (UF6) forTransportation04/30/90All Uranium FuelFabrication and ConversionFacilities90-2490-2090-16Transportation of ModelSPEC 2-T RadiographicExposure DevicePersonnel InjuriesResulting from ImproperOperation of RadwasteIncineratorsCompliance with NewDecommissioning RuleReciprocity: Notificationof Agreement State RadiationControl Directors beforeBeginning Work in AgreementStatesAccidental Disposal ofRadioactive MaterialsExtended Interim Storage ofLow-Level Radioactive Wasteby Fuel Cycle and MaterialsLicensees04/10/9003/22/9003/07/9003/07/9003/06/9002/05/90All NRC licenseesauthorized to use,transport, or operateradiographic exposuredevices and sourcechangersAll U.S. NRC licenseeswho process or incinerateradioactive wasteAll materials licenseesAll holders of NRCmaterials licenses thatauthorize use of radio-active material attemporary job sitesAll NRC byproductmaterials licenseesAll holders of NRCmaterials licenses90-1590-1490-09Correct Number for IN 90-01 should be 9001080145.
Attachment 3IN 90-35May 24, 1990 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to90-34Response toActivationsFalse Siren5/10/90All holders of OLsor CPs for nuclearpower reactors.90-3390-3290-3190-3090-2990-2890-27Sources of UnexpectedOccupational RadiationExposures at Spent FuelPoolsSurface Crack and SubsurfaceIndications in the Weld ofA Reactor Vessel HeadUpdate on Waste Form andHigh Integrity ContainerTopical Report ReviewStatus, Identificationof Problems with CementSolidification, andReporting of Waste MishapsUltrasonic InspectionTechniques for DissimilarMetal WeldsCracking of Cladding andIts Heat-Affected Zone inthe Base Metal of a ReactorVessel HeadPotential Error in HighSteamline Flow SetpointClarification of theRecent Revisions to theRegulatory Requirementsfor Packaging of UraniumHexafluoride (UF 6) forTransportation5/9/905/3/905/4/905/1/904/30/904/30/904/30/90All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors, fuelcycle licenses, andcertain by-productmaterials licenses.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for BWRs.All uranium fuelfabrication andconversion facilities.OL = Operating LicenseCP = Construction Permit