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 

8212060377 
.

                                                            IN 83-10      
                                                            March 11, 1983 
                                                            Page 2 of 3   

     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 
.

                                                            IN 83-10      
                                                            March 11, 1983 
                                                            Page 3 of 3   

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:
List of Recently Issued Information Notices