Information Notice No.80-32, Revison 1 – Clarification of Certain Requirements for Exclusive-Use Shipments of Radioactive Materials

                                                       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 Those paragraphs and appendices are superceded as follows: 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.