Information Notice No. 81-02: Transportation of Radiography Devices

                                                            SSINS No.: 6870 
                                                            Accession No.: 
                                                            808220287      
                                                            IN 81-02       

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555
                                     
                              January 23, 1981

Information Notice No. 81-02:   TRANSPORTATION OF RADIOGRAPHY DEVICES 

Background: 

Recent 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 DOT 
regulations in 49 CFR 170-178 as direct NRC requirements (see 10 CFR 71.5). 

The nature of radiography operations is somewhat 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 caused some confusion on the part of 
radiography users, particularly with respect to sorting out the transport 
regulatory requirements of 49 CFR/10 CFR 71 from the operational 
requirements of 10 CFR 34 and the specific license which has been issued to 
the radiography user. 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. 

This notice discusses some of the pertinent transportation requirements for 
radiography devices when used as transport "packages." The explanations 
should help to clarify the application of operational licensing requirements
versus transport requirements applicable to shippers and carriers, thereby 
enhancing regulatory compliance with the requirements. 

Discussions: 

Source Design -- Radiography sources contained within a device are always 
encapsulated (Co-60 or Ir-192) and, therefore, meet the physical integrity 
requirements of "special form" as defined in 49 CFR 173.389(g) and 
173.398(a). Radiography transporters are reminded that these requirements 
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 to demonstrate that it meets the special 
form requirements. This does not mean that each shipper has to actually 
perform the tests, only that he obtain and retain the documentation of the 
tests. As a practical matter, each radiographer should establish in his 
records a file of such data for each source design in his inventory. It may 
be necessary, therefore, for the radiographer to request the required 
information from his source supplier. 
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Package Design -- Radiography sources in special form will constitute a Type
B quantity when in excess of 20 ci, with Type B packaging required for 
transportation purposes. An exception to this rule is the DOT Specification 
55 (referred to as "Spec. 55") which is not necessarily a Type B package 
(see 49 CFR 178.250; note that DOT no longer includes this specification in 
its annual printing of 49 CFR). Spec. 55 (see Appendix A) is authorized for 
limited Type B quantities (up to 300 ci) of special, form radioactive 
materials in domestic shipments only [see 49 CFR 173.394(b)(1)]. Under this 
provision, however, only Spec. 55 devices that were constructed prior to 
March 31, 1975 are authorized (DOT has recently announced its intention to 
"phase out" DOT Spec. 55; see 44 Federal Register 1852, Part II, January 8, 
1979.) 

For those radiography devices that exceed 20 Ci activity and are not 
contained in DOT Spec. 55, an NRC Certificate of Compliance (COC) must be 
issued pursuant to 49 CFR 173.393a and 173.394(b)(3). Such approved designs 
may be used by other than the original COC applicant provided that such user
registers with the NRC Office of Nuclear Materials Safety and Safeguards 
(NMSS), has a copy of the applicable COC, and complies with its terms and 
conditions [see 10 CFR 71.12(b)]. 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 reports, "Directory of Certificates of 
Compliance for Radioactive Materials Packages" (NUREG-0383), which is 
updated annually. 

CAUTION:  The fact that 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 it has been approved as a 
          Type B transport package pursuant to 10 CFR Part 71. 

Specification Overpacks -- Pursuant to 49 CFR 173.394(b)(5) and (6) and 
173.394(c)(4), Spec. 55 packages may be used to transport quantities of 
activity exceeding 300 ci (domestic service) or 20 ci (international 
service), provided that a Spec. 20 WC (49 CFR 178.194) or Spec. 21 WC (49 
CFR 178.195) protective overpack is used. Again, however, this authorization 
is restricted to the use of Spec. 55 packages constructed prior to March 31,
1975. For international shipments, shippers must additionally register as a 
user under the applicable DOT Certificate of Competent Authority issued by 
that agency pursuant to 49 CFR 173.393b. DOT further requires that this 
certificate be supplied to the foreign consignee and Competent National 
Authority of the destination country. 

Type A Packages -- For radiography devices not exceeding 20 ci of activity 
as special form, the applicable transport specification is either DOT Spec. 
7A [49 CFR 173.394(a)(1) and 178.350] or Spec. 55 [49 CFR 173.394(a)(2) and 
178.250]. For Spec. 7A, as in the case of a special form source, DOT 
regulations require that each shipper of a Spec. 7A package maintain on file
written documentation attesting to the results of the Spec. 7A performance 
tests performed on the package design [49 CFR 173.394 (a)(1)]. 
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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 supplier/user or to perform the tests. 

Package Labeling -- Each radiography device (package) must be properly 
labelled with the appropriate category of RADIOACTIVE label in accordance 
with 49 CFR 172.403(a) through (d). This requires affixing two labels, with 
one label on each of two opposite sides of the package, based on the 
radiation 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 3 ft from any point on
the surface [49 CFR 173.393(i)]. 

A question frequently arises regarding the labeling of radiography devices 
when enclosed in an outer "convenience" box, enclosure, foot locker, etc., 
during transportation. The question is whether or not the radiation levels 
at the surface of such an outer enclosure may be used to establish the 
labeling requirements for the overall "package." Since this situation's not 
addressed in 49 CFR, it is permissible to use such enclosures and to 
establish labeling on the basis of the dose rates at the exterior of the 
outer enclosure.  Assuming that the inner component (the device) is a proper
DOT Spec. 55 device or 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)] and also be labeled as required based on the dose rates at the 
surface and 3 ft from the outer enclosure. 

CAUTION:  The fact that a particular device has been issued an NRC 
          certificate of compliance 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. 

Packages exceeding the limits of 49 CFR 173.393(i) may be transported in a 
closed, exclusive-use vehicle, such as a radiographer's van, provided that 
the following limits are met: 

     1,000 mrem/hr at 3 ft from the external surface of the package, 
     200 mrem/hr at any point on the external surface of the vehicle, 
     and 10 mrem/hour at 6 ft from the vehicle [49 CFR 173,393 (j)]. 

This means that a radiographer may transport a package reading more than 200
mrem/hr at the surface, but less than 1000 mrem/hr at 3 ft from the surface,
in his own exclusive-use vehicle. The radiographer may not deliver the same 
package to a carrier for transport unless the carrier's vehicle is consigned
for the radiographer's exclusive use. 
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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 172.203(d) 
for radioactive material, including the following: 

1.   The DOT proper shipping name. (For radiography devices, this will 
     always be "RADIOACTIVE MATERIAL, SPECIAL FORM-N.O.S"). 

2.   The name of each radionuclide. 

3.   A description of the physical and chemical form of the material. 
     (For radiography sources this description is "SPECIAL FORM"). 

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 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 or medical diagnosis 
     or treatment must also be included [49 CFR 172.204(a), 172.204(c)(3), 
     (4), and (d)]. 

     NOTE:     Most radiography shipments would therefore not 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 173.393(j). 

     NOTE:     The repetitive nature of radiography transportation lends 
               itself to the preparation, of a "permanent" type of shipping 
               paper documentation that is specific to each particular 
               source/device configuration. Such documentation could even 
               take the form of laminated cards retained in the vehicle 
               glove compartment. 

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 172.506 and 172.508) if any quantity of packages bearing the 
RADIOACTIVE-YELLOW III labels is to be carried in the vehicle. For packages 
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tendered to a common motor carrier, the licensee must provide the required 
placards to the carrier at the time the packages are picked up. 

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 frequently occur wherein devices are 
thrown off 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). 

Recommended Action 

Licensees should 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 Fuel Facility and Materials 
Safety Branch of the appropriate Regional Office. 

Enclosures:
1.   Appendix A, DOT Specification 55
2.   Table I