United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 90-35: Transportation of Type A Quantities of Non-Fissile Radioactive Materials

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
              OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
                           WASHINGTON, D.C.  20555

                                May 24, 1990


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 commonly 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 information 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 
applicability 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 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, 




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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 information from the source or device manufacturer. 

Type A vs. Type B Package Determination 

Normal form materials in quantities no greater than applicable A2 limits 
(curies), specified in 49 CFR 173.435, may be shipped in a package called a 
"Type A" 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 A1 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 A1 and A2 limits (in curies) from 49 CFR 173.435 are as follows:

___________________________________________________________________________

Radionuclide                  A1(special form)        A2(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
___________________________________________________________________________
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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 A1 
limit) and normal form (the A2 limit).  This contrasts with CS-137, where 
any quantity exceeding 10 curies (the A2 limit) in normal form requires Type 
B packaging, and as much as 30 curies (the A1 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."  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 A2 limits (in 
curies) specified in 49 CFR 173.435.  Similarly, special form materials that 
do not exceed the A1 limits (which, for certain materials, may be higher 
than the A2 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 173.4l5(a).  This is a pure "performance" specification and is 
not based on any specific and detailed design specifications.  For 
Specification 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 requirements 
described in 49 CFR 173.411-412. 

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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-II, 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 excepted 
from labeling.) 
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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," 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 "Radio-
     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.  
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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-III 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 information 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.) 


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A Caution - Obtain a Copy of the Regulations ! 

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 
radioactive packages are urged to avail themselves of up-to-date copies of 
the applicable 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 
currently 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. 




                              Elizabeth Q. Ten Eyck, Acting Director 
                              Division 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
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                                                            Attachment 1 
                                                            IN 90-35 
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                                                            Page 1 of 1 


                                 REFERENCES 


1.   U.S. Nuclear Regulatory Commission, 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 (DOE/DO/0053-H1), March 1987. 

6.   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 CFR 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. 
     
.ENDEND
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