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SSIN No.: 6835 Accession No.: 8107230047 IN 80-32, Rev. 1 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 February 12, 1982 Information Notice No. 80-32 Rev. 1: CLARIFICATION OF CERTAIN REQUIREMENTS FOR EXCLUSIVE-USE SHIPMENTS OF RADIOACTIVE MATERIALS This is a supplement to Information Notice No. 80-32, originally issued August 29, 1980. It is intended to clarify Question/Answer Numbers 1, 5 and 6 and Appendices A and B on which there have been numerous questions and inquiries. Those paragraphs and appendices are superceded as follows: 1. Q. What radiation limits would apply to shipments being transported on an open exclusive-use transport vehicle? A. The constraints of 49 CFR SS173.393(j)(3) and (4) would apply; e.g., 10 mrem/hr at 2 meters from the open planes projected by the outer lateral edges of the vehicle, and 2 mrem/hr in any normally occupied area of the vehicle (cab). Note: As a matter of clarification, it is important to point out that, in its queries to the Department of Transportation (DOT) on the correct interpretation of SS173.393(i) and (j), NRC has been advised that the existing language of SS173.393(j) does not clearly reflect the original intent of the regulation; i.e., to limit the radiation level at the accessible exterior surface of a package on an open exclusive-use vehicle to 200 mrem/hr (such as the same limit applied to the surface of a closed transport vehicle). DOT has stated that it is currently taking steps to revise SS173.393(j). In the interim, NRC licensees are urged and cautioned to adhere to a surface radiation level limit of 200 mrem/hr on a package transported on an open exclusive-use transport vehicle, as has been the practice and interpretation of most shippers in the past. 5. Q. If "packages," such as secondary inner drums, (as contrasted to a simple personnel barrier as discussed in Q.4 above), are enclosed within an outer shield, may this shield be considered to be an integral part of the "closed transport vehicle" when such a shield provides attenuation of the vehicle radiation levels to meet the 200 mrem/hr limit of SS173.393(j)(2)? Further, what other considerations are there in such a situation in determining what constitutes the "package" as opposed to the "vehicle"? A. This question of defining what constitutes the "package" has arisen frequently and has created much confusion. Generally speaking, the criteria to be considered, which are illustrated in Appendix B, include the following factors: . IN 80-32, Rev. 1 February 12, 1982 Page 2 of 2 o Whether or not any single inner container, e.g., drum has a radiation level of less than l rem/hr at 3 feet [SS173.393(j)(1)] o Whether or not any single inner container, if bearing LSA material, has a quantity of radioactivity exceeding Type A [SS10 CFR 71.7(b), 71.11(b)(1), 71.12(b) and 71.35]. Given the above considerations and the DOT definitions of "closed transport vehicle" [SS173.389(q)] and "packaging" (SS171 8), each inner drum within an outer shield integrally attached to the vehicle may be considered a provided that each inner drum compiles with SS173.393(j)(1), (1 rem/hr at 3 ft) and also provided that the content within any single inner drum does not exceed a Type A quantity of LSA material. In this configuration, the outer enclosure may be considered as the closed transport vehicle and may incorporate integral shielding to meet the vehicle limit of SS173.393(j)(2) (200 mrem/hr). The inner drums would be marked as packages and the outer enclosure placarded as a vehicle. 6. Q. In contrast, under what circumstances would the outer enclosure plus its secondary inner containers, taken together, be considered as the "package"? A. The combination of inner containers plus the outer shield are considered the "package" if any single inner container has a quantity of radioactivity as LSA exceeding Type A or if any single inner container exceeds the limit of SS173.393(j)(1) [1-rem/hr at 3 ft]. Such "packages" must be certified as Type A by the NRC Office of Nuclear Materials Safety and Safeguards. No written response to this notice is required. If you need additional information regarding this subject, contact the Regional Administrator of the appropriate NRC Regional Office. Attachments: 1. Appendices A and B 2. Recently issued Information Notice No.
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