Information Notice No. 83-10: Clarification of Several Aspects Relating to Use of NRC-Certified Transport
SSINS NO. 9196
IN 83-10
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D. C. 20555
March 11, 1983
Information Notice No. 83-10: CLARIFICATION OF SEVERAL ASPECTS RELATING
TO USE OF NRC-CERTIFIED TRANSPORT
PACKAGES
Addressees:
All NRC-licensed reactor facilities and registered users of NRC-Certified
transport packages.
Purpose:
The NRC's Office of Nuclear Materials Safety and Safeguards (NMSS) has
identified a need to clarify certain matters relating to the use of NRC-
Certified packages. These matters are discussed below.
Discussion:
Temporary Shielding - Pursuant to 10 CFR 71.22, an applicant for an NRC
Certificate of Compliance for a Radioactive Materials Package must include
with his application a "description of the proposed package in sufficient
detail to identify the package accurately and to provide a sufficient basis
for evaluation of the packaging." For some packages, it may be desirable to
add temporary gamma shielding as an auxiliary component of the packaging. In
these cases the additional inclusion of such shielding to the package must
have been specifically addressed in the package application and thereby
authorized in the Certificate of Compliance. In addressing such temporary
shielding, the applicant must demonstrate that the shielding remains
effective during the applicable normal and/or accident conditions of
transport. In other words, the use of such temporary additional shielding
(such as metal shoring or lead sheets), banded or attached to the package so
as to conform to applicable regulatory limits for external radiation, would
not be authorized unless it is specifically provided for in the Certificate
of Compliance issued by NMSS. The above requirements would not, of course,
apply to any temporary shielding which is not attached to the package, whose
sole purpose is to reduce external radiation dose rates below regulatory
requirements (e.g., additional shielding attached to the sides of the
trailer or truck cab).
Preparation and Assembly -- Pursuant to 10 CFR 71.54, a shipper/licensee
must determine that a package satisfies the applicable package standards,
and in addition, determine that among other things, for each shipment:
1. the packaging has not been significantly damaged;
2. the closure of the package and any sealing gaskets are present and
free from defects; and
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3. the package has been loaded and closed in accordance with written
procedures.
In making the above determinations, several cautions should be observed:
1. The packaging should be considered significantly damaged if such
damage would be likely to preclude the package from meeting the
applicable requirements of 10 CFR 71.
2. Closures which involve attempts at sealing with gaskets having
visible or obvious imperfections, such as cracked or missing
pieces, field splices, or caulking and rusty or dirty sealing
surfaces would not be considered to be free from defects; and
3. The loading and closing of packages in accordance with written
procedures should include a determination that the packaging is
authorized for the specific intended contents, and that any lid/
closure to main body is properly aligned, with its bolts properly
torqued to the specified values in the prescribed pattern.
Quality Assurance -- For all shipments under the general license provisions
of 10 CFR 71.12, it is required that the shipper have a quality assurance
program which has been approved by NRC as satisfying the provisions of 10
CFR 71.51. Frequent questions have arisen concerning the fulfillment of this
requirement in those cases where there are, multiple users, as in the case
of leased casks. The NMSS position on this is as follows:
1. Each registered licensee-user should obtain a current certificate
from the package owner attesting that the packaging was designed,
procured, fabricated, assembled, tested, modified, repaired, and
is maintained in accordance with an NRC-approved quality assurance
program.
2. Each registered licensee-user should provide the owner with a copy
of all quality assurance records concerning maintenance, repair,
or modifications to the package which are conducted under the
licensee-user's quality assurance program.
3. Each licensee-user should maintain its own quality assurance
program and related records concerning its use/operation and
maintenance of the package. The licensee-user is also encouraged
to obtain from the package owner copies of those quality-related
documents which may be useful and relevant to the licensee-user's
own quality assurance program. (Note: This is not to imply
necessarily that the package owner would be expected to provide
each user, nor is each user expected to maintain all of the
quality-related documents associated with all of the criteria of
10 CFR Part 71 Appendix E.)
Recognizing the inherent difficulties in maintaining quality assurance
records in cases of multi-user packages, it is important to bear in mind
that the individual licensee-user is responsible for maintaining as complete
a file as possible of
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the quality assurance records pertaining to package use, and further, to
establish mechanisms for exchange of pertinent quality assurance records
with the package owner. It remains the responsibility of each licensee-user
that its transportation activities meet the requirements of 10 CFR 71. As
stated above, however, in fulfilling this responsibility the licensee-user
has the prerogative to accept written certifications from package owners and
suppliers that certain quality assurance activities, not under the
licensee-user's immediate control, were conducted in accordance with an
NRC-approved quality assurance program.
Further guidance on acceptable quality assurance programs is provided in NRC
Regulatory Guide No. 7.10 which was issued in January 1983.
Contamination Surveys -- A question sometimes arises concerning the
performance of contamination surveys pursuant to 49 CFR 173.393(h),
173.393(n)(9), 173.397, and 10 CFR 20.205(b) in those cases where a package,
such as a cask, is provided with an external heat barrier or screen to
achieve compliance with the heat limits of 49 CFR 173.393(e). The question
is whether the contamination limits, as measured by wipe tests, may be taken
at the surface of the external barrier or at the surface of the cask within
the barrier screen. It is the NMSS position that the contamination limits of
49 CFR 173.397 must be applied at the package surface (including the
surfaces between the package and any removable impact limiter) even though
the heat limit of 49 CFR 173.393(e) is applied at the barrier surface.
Monitoring of contamination levels' at the outer barrier screen might not
disclose the existence of contamination from the package or on the package.
Monitoring of the surface contamination of the cask inside the barrier is
therefore a regulatory requirement, whereas monitoring of both the cask
surface and the outer barrier would constitute a better health physics
practice.
No written response to this notice is requested. If you need additional
information, please contact the appropriate NRC Regional Office.
James M. Taylor, Director
Division of Quality Assurance, Safeguards,
and Inspection Programs
Office of Inspection and Enforcement
Technical Contact:
A. W. Grella, 492-7746
Attachment:
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