U.S. Nuclear Regulatory Commission

Packing Greater Than Type A Quantities of LSA Radioactive Material for Transport

HPPOS-080 PDR-9111210216

Title: Packing Greater Than Type A Quantities of LSA

Radioactive Material for Transport

See IE Circular No. 78.03 entitled as above and dated May

12, 1978. This circular describes a situation at nuclear

power facilities that could occur wherever greater than

Type A quantities of low specific activity (LSA)

radioactive materials are packaged for transport. Shipment

of greater than Type A quantities of LSA material may be

done only in packages certified by NRC under 10 CFR Part

71. Department of Transportation (DOT) regulations require

"strong, tight packages" for LSA material and make no

mention of total activity that may be shipped.

Some licensees subject to the requirements of 10 CFR Part

71 have shipped packages containing greater than Type A

quantities of LSA material in packages which are not

authorized by NRC. These unauthorized shipments have

resulted from an inadequate understanding of Part 71

regarding LSA material. Differences between Part 71 and DOT

requirements in 49 CFR Parts 170 to 189 have apparently

contributed to these misunderstandings.

Specifically, 49 CFR 173.392 authorizes the shipment of LSA

material in "strong, tight packages" when transported in

vehicles assigned for the sole use of the consignor. DOT

regulations make no mention of the total activity that may

be shipped in this manner. On the other hand, NRC

regulations (10 CFR 71.3) require that no licensee shall

(a) deliver any licensed materials to a carrier for

transport or (b) transport licensed material except as

authorized in a general or specific license issued by the

NRC, or as exempted in Part 71. The general license of 10

CFR 71.12 has requirements for the type of container when

more than a Type A quantity of radioactive material is to

be transported. LSA material in excess of a Type A

quantity is not exempt from the general license

requirements. Several Licensees have failed to recognize

the difference between the DOT and NRC requirements and

have packaged greater than Type A quantities of LSA

material for transport in containers other than those

authorized by the general license of 10 CFR 71.12.

Compliance with Part 71 is the responsibility of the NRC

licensee who delivers licensed material to a carrier for

transport or who transports such materials outside the

confines of its plant or other place of use.

Regulatory references: 10 CFR 71.2, 49 CFR 173

Subject codes: 12.17

Applicability: All