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SSINS No.: 6835 IN 87-47 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, DC 20555 October 5, 1987 Information Notice No. 87-47: TRANSPORTATION OF RADIOGRAPHY DEVICES (Update of Information Notice No. 81-02, January 23, 1981) Addressees: All NRC licensees authorized to manufacture, distribute and/or operate radio- graphic exposure devices and/or source changers. Purpose: This notice is provided to remind licensees of the pertinent transportation requirements for radiography devices when used as transport "packages." The following explanations should help to clarify the application of operational licensing requirements versus transport requirements applicable to shippers and carriers, thereby prompting improved regulatory compliance with these requirements. Requirements for a license are attached. It is suggested that licensees review this information for applicability to their operations involving transportation of radiography devices, and consider actions, if appropriate, to preclude violations of the transport regulatory requirements. However, suggestions contained in this notice do not constitute NRC requirements; therefore, no specific action or written response is required. Description of Circumstances: Inspections by NRC have identified frequent noncompliance with transportation regulations by radiography licensees. As of December 3, 1979, the NRC inspection program has included inspection/enforcement of U.S. Department of Transportation (DOT) regulatory requirements in 49 CFR 170-189 as direct NRC requirements (see 10 CFR 71.5). The nature of radiography operations is unique in that radiography devices most frequently serve a dual function; that is, they serve as operational radiography cameras/source changers and as transportation packages. Historically, this has 8709300050 . IN 87-47 October 5, 1987 Page 2 of 6 caused some confusion for radiography users, particularly with respect to sorting out the transport regulatory requirements of DOT/NRC from the opera- tional requirements of 10 CFR 34 and the specific license which has been issued to the user of radiography devices. Another source of confusion for the radiography operator is that he most frequently functions, with respect to the transportation regulations, in the dual role of both shipper and carrier. Discussion: Source Design -- Radiography sources contained within a device are always encapsulated radioactive material (Co-60 or Ir-192). They should meet the physical integrity requirements of "special form," as defined in 49 CFR 173.403(z) and 10 CFR 71.4. Radiography transporters are reminded that requirements in 49 CFR 173.476(a) call for each shipper of a special form source to maintain a file of supporting safety analysis or documentation containing the results of the testing performed on the source design to demonstrate that it meets the special form requirements. This does not mean that each shipper has to actually perform the tests, only that the shipper obtain and retain the documentation of the tests. As a practical matter, each radiographer should establish a file of such data for each source design that is used. It may be necessary, therefore, for the radiographer to request the required information from the source manufacturer/supplier. Package Design -- Radiography sources in special form will constitute a Type B quantity of radioactive material, with Type B packaging required for transportation purposes, when the activity is in excess of a A1*curies (A1Ci). Issuance of an NRC Certificate of Compliance is a necessary prerequisite to the use of a radiography device containing a special form source that exceeds A1 curies. For those radiography devices that exceed A1 activity, an NRC Certificate of Compliance (COC) must be issued, as required by 10 CFR 71.12 and 49 CFR 173.416(b). Such approved devices may be used by other than the original COC applicant, provided that such user registers with the NRC Office of Nuclear Material Safety and Safeguards (NMSS), has a copy of the applicable COC, and complies with its terms and conditions (see 10 CFR 71.12). A listing of radiography devices for which NRC has issued a COC is given in Table 1 (see Enclosure 2). Copies of COCs are included in the NRC/NMSS report, "Directory of Certificates of Compliance for Radioactive Materials Packages" (NUREG-0383), which is updated annually. (Devices which were manufactured to the now obsolete DOT Spec. 55 are no longer authorized for transportation unless enclosed in a DOT specification overpack. See specification overpacks below.) ____________________ *A1 = maximum activity permitted in a Type A package when the material is in "special form." For Ir-192, A1 = 20 Curie; for Co-60, A1 = 7 Curie (defined in 49 CFR 173.403(a) and 10 CFR 71.4. There are tables of A1/A2 values for radionuclides in 49 CFR 173.435 and in 10 CFR 71, Appendix A). . IN 87-47 October 5, 1987 Page 3 of 6 CAUTION: The fact that the use of a radiography device has been approved by NRC under a specific license provision pursuant to 10 CFR Part 34 as an operational device does not mean that NRC has approved it as a Type B transport package pursuant to 10 CFR Part 71. For international shipments, shippers must additionally register with DOT as users of the DOT Certificate of Competent National Authority pursuant to 49 CFR 173.472. DOT further requires that this certificate be supplied to the foreign consignee and Competent National Authority of the destination country and other countries through which the package will be transported. Specification Overpacks -- Pursuant to 49 CFR 173.416(f) or (g), DOT Spec. 55 packages may be used to transport quantities of activity exceeding A1Ci of special form radioactive material provided that a Spec. 20 WC (49 CFR 178.194) or Spec. 21 WC (49 CFR 178.195) protective overpack is used. However, this authorization is restricted to the use of Spec. 55 packages constructed before April 31, 1975. Type A Packages -- For radiography devices containing special form sources not exceeding A1Ci of activity, the authorized packages are stated in 49 CFR 173.415. As a practical matter, the DOT Spec. 7A [49 CFR 173.415(a) and 178.350] is most frequently applicable. DOT regulations require that each shipper of a Spec. 7A package maintain on file written documentation showing that the construction methods, packaging, design, and material of construction comply with that specification [see 49 CFR 173.415(a)]. If the shipper of a Spec. 7A package is not the original designer or user of that package, it will be necessary for the shipper to obtain the test report data from the original designer/user or to perform and document the tests on his own [see 49 CFR 173.415(a) and 173.475]. Package Labeling -- During transportation each radiography device (package) must be properly labelled with the appropriate category of RADIOACTIVE label in accordance with 49 CFR 172.403. This requires affixing two labels on opposite sides of the package. The type of label is based on the radiation levels at the surface of the package and at 1 meter. The 1 meter dose rate determines the transport index (TI) that is indicated on the label. Additionally, the label must contain isotope and activity. The dose rates are limited to 200 mrem/hr at contact with any point on the external surface of the package and 10 mrem/hr at 1 meter from any point on the external surface of the package [10 CFR 71.47 and 173.441(a)]. A question frequently arises regarding the labeling of radiography devices when enclosed within an outer "convenience" box, enclosure, foot locker, etc., during transportation. The question is whether the radiation levels at the surface of such an outer enclosure may be used to establish the labeling requirements for . IN 87-47 October 5, 1987 Page 4 of 6 the overall "package." It is permissible to use such enclosures and to estab- lish labeling on the basis of the radiation levels at the exterior of the outer enclosure. Assuming that the inner component (the device) is designed according to NRC/COC requirements, and is marked as such, the outer enclosure would also have to be marked with the words "Inside Package Complies with Prescribed Specification" [see 49 CFR 173.25(a)]. It must also be labeled, as required, based on the dose rates at the external surface of the package and at 1 meter from the outer enclosure. CAUTION: The fact that a particular device has been approved in an NRC COC does not necessarily mean that, when fully loaded with its contents as authorized in a specific license, the dose rates will be within the regulatory limits. Each package must be surveyed to assure that proper labeling is applied and the appropriate IT is present thereby. Packages exceeding the limits of 49 CFR 173.441(a) may be transported in a closed, exclusive-use vehicle, such as a radiographer's van (but not an open pickup truck), provided that the following limits are not exceeded: 1,000 mrem/hr on the external surface of the package, 200 mrem/hr at any point on the external surface of the vehicle, and 10 mrem/hr at 2 meters from the lateral surfaces of the vehicle [49 CFR 173.441(b)]. This means that a radiographer may transport a package reading more than 200 mrem/hr at the surface, but not more than 1000 mrem/hr at the surface, in the radiographer's own exclusive-use vehicle [see 49 CFR 173.403(i)]. The radio- grapher may not deliver the same package to a carrier for transport unless the carrier's vehicle has been consigned for the radiographer's exclusive use. Shipping Papers -- A shipping paper is required for each transfer of radioactive material from the confines of the licensee's plant, whether transported by the licensee or delivered to a carrier for transport. The shipping paper must include the information required by 49 CFR 172.202 and 172.203(d) for radioactive material, including the following: 1. The DOT proper shipping name. (For radiography devices, this will usually be "RADIOACTIVE MATERIAL, SPECIAL FORM N.O.S".) See 49 CFR 172.101. Also, the hazard identification number for special form is: "UN2974." NOTE: For packages containing a special form source wherein the A1limit equals the A2 limit for the specific nuclide, e.g., Co 60, it is suggested that the DOT proper shipping name and hazard identi- fication of "RADIOACTIVE MATERIAL, N.O.S" and "UN2982" be used. This will obviate the necessity to obtain the special form testing documentation. [See 49 CFR 173.476(c)] 2. The name of each radionuclide. 3. A description of the physical and chemical form of the material. For special form sources, this description is "SPECIAL FORM." In cases where A1= A2 and the special form proper shipping name is not used, a typical radionuclide name and description might be "Cobalt-60 as contained within a welded, hermetically sealed stainless steel capsule." . IN 87-47 October 5, 1987 Page 5 of 6 4. The activity contained in each package measured in curies. 5. The category of label applied to each package (RADIOACTIVE WHITE-I, RADIOACTIVE YELLOW-II, OR RADIOACTIVE YELLOW-III.) 6. The transport index assigned to each package bearing RADIOACTIVE YELLOW-II or RADIOACTIVE YELLOW-III labels. 7. The package certificate identification, if it is an NRC-certified package. 8. For shipments tendered to a common carrier, the appropriate signed shipper's certification, and, for shipments by aircraft, the additional statement of "cargo aircraft only." NOTE: No industrial radiography shipments would be authorized for passenger-aircraft shipments, since the intended use of the radiography equipment is not for research or medical applications. 9. Instructions for maintenance of exclusive-use shipment controls, in the case of packages transported with the higher dose rates allowed by 49 CFR 173.441(b). [See 49 CFR 173.441(c).] NOTE: The repetitive nature of radiography transportation lends itself to the preparation of a "permanent" type of shipping paper docu- mentation that is specific to each particular source/device con- figuration. Such documentation could even take the form of laminated cards which are retained and accessible within the vehicle. [See 49 CFR 177.817(e).] Vehicle Placarding -- The transport vehicle must be placarded by the licensee on the front, rear, and each side with the appropriate DOT placard (see 49 CFR Part 172.500-172.519, 172.556 and Appendices B and C) if any package bearing the RADIOACTIVE YELLOW-III label is to be carried in the vehicle. For a YELLOW-III labeled package tendered to a common motor carrier, the licensee must provide the required placards to the carrier at the time the packages are picked up, unless the carrier's vehicle is already placarded as required. NOTE: DOT placard requirements should not be confused with radiography area posting requirements of 10 CFR 20.203 and 34.42. Securing Cargo within Vehicle -- Radiography licensees who transport devices (packages) in their own vehicles must provide for adequate blocking, bracing, or tie-down of the package to prevent its shifting or movement during normal transport. Incidents have occurred where devices are dropped and lost from moving vehicles, often without the driver's awareness. These incidents are usually caused by the failure to properly secure the device, combined with a failure to secure the cargo door of the vehicle. Recent cases of this type have resulted in civil penalty for failure to comply with 49 CFR 177.842(d). (See Information Notice No. 87-31, July 10, 1987.) . IN 87-47 October 5, 1987 Page 6 of 6 It is suggested that licensees review all movements of radiography devices away from their place of storage to ensure that they are (1) using appropriate packages; (2) properly controlling radiation levels on packages shipped; (3) providing proper shipping documents, and (4) following the applicable carrier requirements when transporting devices in their own vehicles. No written response to this notice is required. If you require additional information regarding this matter, contact the appropriate NRC Regional Office or this office. Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical Contacts: A. W. Grella, NMSS/SGOB (301)427-4709 S. Baggett, NMSS/IMAB (301)427-9005 Attachments: 1. Requirements for a License 2. List of Radiography Devices and Containers having NRC Certificates of Compliance 3. List of Recently Issued NRC Information Notices . Attachment 1 IN 87-47 October 5, 1987 REQUIREMENTS FOR A LICENSE The scope of 10 CFR Part 71, as defined in . 71.0(c) includes all specific licensees of the Commission if the licensee delivers radioactive material to a carrier for transport or transports the material outside the confines of his facility, plant, or other authorized place of use. This scope includes all radiographers licensed under 10 CFR Part 34, including those who conduct radiographic operations in the field, those who transport replacement sources, or who deliver replacement sources to a carrier for transport. Section 71.3 "Requirement for License" in 10 CFR Part 71 prohibits any such transport or delivery to a carrier except as authorized in a general license or a specific license issued by the Commission, or as exempted in Part 71. Specific licenses issued under 10 CFR Part 34 are not intended to satisfy this requirement for a license prescribed by . 71.3. In most cases, the general licenses containing .. 71.12, 71.14, and 71.16 of 10 CFR Part 71 are adequate to satisfy the requirement for license as applied to radiographers. Any specific license issued to satisfy this requirement would be issued pursuant to 10 CFR Part 71. The three general licenses in 10 CFR Part 71, in .. 71.12, 71.14, and 71.16, have conditions which apply to transportation of radiography devices or source exchangers. The user of the Part 71 general license (usually the shipper and frequently also the carrier of the radiographic exposure device) must register as a user of the general license with NRC and must have an approved quality assurance program which satisfies the previsions of Part 71, Subpart H (see . 71.101, "Quality Assurance Requirements").
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