Information Notice No. 82-47: Transportation of Type a Quantities of Non-Fissile Radioactive Material
SSINS NO.
IN 82-47
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
November 30, 1982
Information Notice No. 82-47: TRANSPORTATION OF TYPE A QUANTITIES OF
NON-FISSILE RADIOACTIVE MATERIAL
Addressees:
All NRC licensees.
Background:
In 1979 the U.S. Department of Transportation (DOT) regulations in 49 CFR
Parts 170-178 were incorporated as requirements in NRC regulations (see 10
CFR 71.5).
During inspections over the past several years, NRC has noted frequent
violations of the regulatory requirements of 49 CFR, particularly in the
case of the licensee who only occasionally packages and ships material
subject to DOT regulations. In most cases these licensees are found to be
generally unfamiliar with and lack knowledge of DOT requirements. In many
instances, the licensee may have never read or even obtained a copy of DOT
regulations.
This information notice is directed to all licensees, but particularly to,
those authorized to possess and use material in industrial, medical, and
academic programs. It contains a discussion of the pertinent packaging and
transportation requirements for Type A packages in special or normal
(non-special) form. These explanations should help clarify the application
of the regulatory requirements and thereby enhance the overall level of
safety and compliance. Information Notice No. 81-02 issued January 23,
1981 provided similar information and guidance peculiar to the
transportation of licensed material in radiography devices.
Discussion:
General
Many licensees perform very little or only occasional activity which
involves preparing and delivering packages of radioactive materials to a
carrier. Some licensees may also transport packages in their own vehicles.
In this case, they play a dual role of shipper and private carrier, thereby
being subject to the requirements for both.
Source Design--Radioactive sealed sources classified as "special form"
material must meet the physical integrity requirements as defined in 49 CFR
173.389(g) and 173.398(a). Any licensee who ships or transports special form
sources is reminded that these requirements call for each shipper of a
special form
8208190257
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IN 82-47
November 30, 1982
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source to maintain on file a 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 must obtain and
retain the documentation of these tests. As a practical matter, each
licensee should establish a file of such data for each source design in his
inventory. It may be necessary, therefore, for the licensee to procure the
required information from the source manufacturer.
In some instances, qualification of the material as special form will have
no bearing on the type of packaging required, relative to content limit, for
example, as in the case of less than 3 Ci of a transport Group III material
such as Cs-137, Co-60, etc, wherein the activity being shipped is less than
the limit for non-special form material in a Type A package. In that case
Type A packaging is required, regardless of "form." This contrasts to
Transport Group I materials, such as Am-241, Po-210, etc.; wherein any
quantity exceeding 1 mCi in non-special form requires Type B packaging and
as much as 20 Ci in special form is allowed in Type A packaging. In either
situation, however, if the material is described as "Radioactive material,
special form, n.o.s." on the shipping papers and package marking, the
shipper is required to maintain the special form documentation prescribed by
49 CFR 173.398 (a), Note 1. As an alternative, to obviate this requirement,
the shipper may elect to describe the material as "Radioactive material,
n.o.s." when the "form" makes no difference relative to type of packaging
used in relation to the activity limit.
Type A Packages--For special form sources not exceeding 20 Ci of activity,,
the applicable transport package specification is either DOT Specification
7A (49 CFR 173.394(a)(1) and 178.350) or Specification 55 (49 CFR
173.394(a)(2) and 178.250). Only specification 55 packagings that were
constructed before March 31, 1975, are authorized (DOT intends to phase out
DOT Specification 55; see 44 Federal Register 1852, Part II, January 8,
1979). Since the Specification 55 is no longer included in current printings
of 49 CFR 178, a copy of that specification (49 CFR 178.250) is included as
Appendix A hereto.
For normal form (non-special) Type A contents, the maximum package activity
must not exceed the applicable Type A limits as specified in SS173.389(1).
The usually applicable package design is the DOT Specification 7A
"performance" specification. (49 CFR 173.395(a)(1) and 178.350).
For Specification 7A, DOT regulations require that each shipper of a
Specification 7A package maintain on file written documentation attesting to
the results of the Specification 7A performance tests performed on the
package design (49 CFR 173.395(a)(1)). 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 report data from the original
supplier/user or to perform the tests himself and document the results.
Further, if a shipper makes any changes to the packaging or its maximum
authorized contents from those as were described on the original test report
furnished by another person, it would be necessary to perform and document a
supplemental evaluation, addressing such changes and demonstrating that the
package would continue to meet the appropriate performance requirements. In
any case, the "bottom line" of the Specification 7A documentation is that
the results of how the package meets the applicable environmental and test
conditions must be addressed.
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Package Labeling--Each package must be properly labeled with the appropriate
category of "RADIOACTIVE" label in accordance with 49 CFR 172.403(a) through
(d). This requires affixing two labels, one on each of two opposite sides of
the package. The appropriate label category to be selected and transport
index entry on the yellow label are based on the radiation dose rates at the
surface of the package and at 3 feet (transport index) from the package.
Pursuant to 49 CFR 173.393(i), the dose rates are limited to 200 mrem/h at
contact with any point on the external surface of the package and 10 mrem/h
at 3 feet from any point on the surface.
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 or delivered to a common 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 applicable DOT proper shipping name from 49 CFR 172.101. (For
sources that are shipped as special form this will always be
"Radioactive material, special form, n.o.s." For non-special form
materials, the shipping name will generally be "Radioactive material,
n.o.s.")
2. The applicable Identification Number (U.N. or NA ) from 49 CFR
172.101
3. The name of each radionuclide.
4. A description of the physical and chemical form of the material. (For
special form sources this description is "SPECIAL FORM". )
5. The activity contained in each package, measured in curie units.
6. The category of label applied to each package ("RADIOACTIVE WHITE-I",
"RADIOACTIVE-YELLOW II", or "RADIOACTIVE YELLOW-III").
7. The transport index (dose rate at 3 feet) assigned to each package
bearing "RADIOACTIVE YELLOW-II" or "RADIOACTIVE YELLOW-III" labels.
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)).
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IN 82-47
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NOTE: The repetitive use of the same design and contents of the
packages which are often involved when licensees transport their own
packages, particularly when in special form, lends itself to the
preparation of a "permanent" type of shipping paper documentation that
is specific to each particular source/device/package configuration.
Such documentation could even take the form of laminated cards retained
in the cab of the vehicle, thereby eliminating the need for preparing a
totally new shipping paper document every time a shipment is made. (See
49 CFR 177.817(e) regarding accessibility of shipping papers within
highway vehicles.)
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 package bears the RADIOACTIVE-YELLOW III
label and for full-load shipments of radioactive materials meeting the
definition of low specific activity when transported as an exclusive use
shipment under the provision of 49 CFR 173.392(b) (Table 1 49 CFR 172.504).
For packages tendered to a common motor carrier, the licensee must provide
the required placards to the carrier at the time the packages are picked up.
Vehicles should not be placarded when the shipment does not include packages
for which placarding is required. (49 CFR 172.502(a)). In addition, enriched
uranium hexafluoride or uranium hexafluoride transported as low specific
activity material must also be placarded as "CORROSIVE" if the shipment
gross weight is 1,000 pounds or more (Table 1, 49 CFR 172.504).
NOTE: 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.
Securing Cargo Within Vehicle--Licensees who transport devices (packages) in
their own vehicles must provide for adequate blocking, bracing, or tie-down
of the package(s) to prevent shifting or movement during normal transport.
Frequently packages or 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 package or 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).
Security of Material During Transport--Licensees who transport radioactive
materials as private carriers in their own vehicles are subject to the
requirements of 10 CFR 20.207 since the possession of the material outside
the licensed facility itself is considered to occur in an unrestricted area.
Licensees are required to provide security measures adequate to prevent the
unauthorized removal of the material from its place of storage during
transport. This requirement sometimes presents problems and difficulties in
cases where the licensee feels it necessary to stop at a restaurant, or
spend the night at a motel, or in traveling to and from temporary job sites.
Nonetheless, at times when the material is neither under constant
surveillance nor attended, it is
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IN 82-47
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necessary to physically secure the material to or within the vehicle. This
may involve locking the package(s) 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. In a
number of cases the packages were secured and locked within the vehicle, but
the keys were left in the ignition, and the vehicle was stolen. Failure to
remove the keys in these cases has been considered a violation of 10 CFR
20.207.
The discussion contained herein is considered informational guidance. All
licensees who package and/or transport radioactive packages are urged to
avail themselves of up-to-date copies of the applicable regulations. Copies
of the regulations can be obtained from Superintendent of Documents, U.S.
Government Printing Office, Washington, D.C. 20402, Telephone (202)
782-3238.
No written response to this notice is required. If you need additional
information, contact the appropriate NRC Regional Office,.
L. I. Cobb, Director
Division of Fuel Facilities, Materials
and Safeguards
Office of Inspection and Enforcement
Technical Contact: A. Grella
492-7746
Attachments:
1. List of Recently Issued IE Information Notices
2. Appendix A
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