Information Notice No. 87-31:Blocking, Bracing, and Securing of Radio-Active Materials Packages in Transportation

		                                         SSINS No.: 6835 
                                                    IN 87-31 

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
                             WASHINGTON, D. C. 20555

                                  July 10, 1987


Information Notice No. 87-31:  BLOCKING, BRACING, AND SECURING OF RADIO-
                                   ACTIVE MATERIALS PACKAGES IN TRANSPORTATION


Addressees: 

All NRC licensees. 

Purpose: 

This notice is provided to remind licensees of their responsibilities to 
ensure the proper blocking, bracing, and securing (tie-down) of radioactive 
materials packages being offered to a carrier, wherein transport by 
exclusive-use vehicle is required, or packages being transported by the 
licensee as a private carrier, whether by an exclusive-use or a 
non-exclusive-use vehicle. 

It is suggested that licensees review this information for applicability to 
their shipping and transportation program and consider actions, if 
appropriate, to preclude similar problems with their shipments.  However, 
suggestions contained in this notice do not constitute NRC requirements; 
therefore, no specific action or written response is required. 

Description of Circumstances: 

There has been evidence of inadequacies in the blocking, bracing, and securing
of packages to the transport vehicle involving packaged shipments of low-
specific-activity (LSA) radioactive material (radwaste) in drums or bins.  The
following are recent, typical examples of such inadequacies: 

     On April 25, 1986, an exclusive-use shipment of LSA waste from a nuclear 
     power plant in the Midwest arrived at the Barnwell, South Carolina waste 
     disposal site.  The inspector for the State of South Carolina who was at 
     the site observed that the three packages on the flatbed trailer had 
     shifted in transit as a result of inadequate blocking and bracing. 

     On July 7, 1986, a nuclear fuel plant in the southeast made a shipment of
     two 10-ton uranium hexafluoride cylinders to the gaseous diffusion plant 
     at Paducah, Kentucky.  After departure, one cylinder broke free and fell 
     from the vehicle onto the ground when the truck made a sudden stop.  Con-
     tributing causes of the load separation were a faulty hold-down strap 
     and inadequate bracing and tie-down of the cylinder and cylinder 
     supports. 


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     On June 5, 1986, an exclusive-use shipment of LSA waste from a nuclear 
     plant in the South arrived at the Barnwell waste disposal site.  When the
     State of South Carolina inspector at the site opened the closed trailer, 
     he observed that the blocking and bracing that had been provided was 
     inadequate to prevent the movement of some drums during transit. 

In each of these instances, enforcement action was taken against the shipper 
for failure to comply with the Department of Transportation (DOT) regulations.

Discussion: 

Section 10 CFR 71.5(a) requires that each licensee who transports licensed 
material outside of the confines of its plant or place of use or who delivers 
licensed material to a carrier for transport, shall comply with the applicable 
requirements of the DOT in 49 CFR Parts 170-189 for the mode of transport 
used.  These requirements apply whether the mode of transport is by rail, air, 
water, or public highway. 

Many packages offered for transport by licensees, including waste shipments, 
qualify as LSA as defined in 49 CFR 173.403(n).  When packaged LSA materials 
are shipped by exclusive-use vehicles, the requirements in 40 CFR 173.425(b) 
must be met. 

In addition to the limits for external radiation levels and removable 
contamination, the other requirements of 49 CFR 173.425(b) should be 
recognized by all licensees.  Specifically, 49 CFR 173.425(b)(4) requires that 
the shipment must be loaded by the consignor (e.g., the licensee shipper) and 
unloaded by the consignee.  Section 49 CFR 173.425(b)(6) requires that the 
shipment must be braced to prevent shifting under normal transportation 
conditions.  Bracing of loads may involve blocking, shoring, tie-downs (chains 
and/or straps), or other restraints. 

For all shipments of radioactive material requiring an exclusive-use vehicle, 
the licensee-shipper is responsible for assuring that the shipment is properly
loaded and secured; it is not the responsibility of the driver or carrier 
company.  In other words, in such cases, the shipper is assigned the responsi-
bility for certain functions that are normally (for non-exclusive-use 
shipments) the responsibility of the carrier.  Section 49 CFR 173.403(i), 
states that "all initial, intermediate, and final loading and unloading are to 
be carried out in accordance with the directions of the consignor or 
consignee."  Blocking, bracing, and tie-downs, therefore, are considered to be 
a part of the loading process and the responsibility of the 
consignor-shipper-licensee for exclusive-use shipments.  If a load shifts 
during normal transport, the licensee bears the responsibility and may be 
subject to enforcement actions under 10 CFR 2 when violations occur.  In some 
cases, the carrier may perform inspections of tie-down provisions during 
transport.  The applicable instruction provided by the shipper to the carrier 
for maintenance of exclusive-use shipment control may provide guidance on this 
subject. 

Pursuant to 49 CFR 177.842(d), radioactive materials packages must be blocked 
and braced such that they cannot change position during conditions normally 
incident to transportation.  This requirement applies to common or contract 
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(i.e., "for-hire" carriers) and private carriers.  Therefore, whether or not 
the shipment is by exclusive-use vehicle, the requirement applies to licensees
that are transporting packages and acting as both a shipper and a private 
carrier; e.g., radiographers, well logging companies, radiopharmacy suppliers,
waste brokers, etc. 

For shipments offered by a licensee-shipper to a common carrier; e.g., partial
loads in a vehicle that is not for exclusive-use, the carrier is ultimately 
responsible for the proper blocking, bracing, and securing of the package.  
All too frequently, incidents occur wherein packages are thrown onto the 
roadway and lost because of the carrier's failure to properly secure the load 
and/or failure to secure the cargo door.  In such cases, the carrier may be 
subject to enforcement actions by the DOT or a State regulatory authority. 

Actions taken by licensees to ensure that shipments are properly loaded and 
braced have included written loading procedures with detailed checklists and 
quality control oversight and release requirements.  When a licensee ships 
several types of packages, detailed procedures with a checklist have been 
prepared for each.  The applicable certificate-of-compliance for an NRC-
certified package may sometimes contain prescriptions for package tie-down 
arrangements. 

Specific regulatory and technical standards for tie-down of packages to 
transport vehicles may be found in: 

     .49 CFR 393.100, 393.102, and 393.104 - for motor vehicles; 

     .10 CFR 71.45(b) - applicable to tie-down attachment points that are 
     structural components of radioactive packages that are subject to the 
     Package Approval Standards of Subpart E of 10 CFR 71; 

     ANSI N-14.2 - Proposed American National Standard "Tie-down for Truck 
     Transport of Radioactive Materials" (currently in the form of Draft 5, 
     Revision 2, September 2, 1986, and available from the Secretary, N14 
     Committee, International Energy Associates Limited, 3211 Jermantown Road,
     Fairfax, Virginia 22030). 

No written response to this information notice is required.  If you have any 
questions regarding this matter, please contact the Regional Administrator of 
the appropriate NRC regional office or this office. 



                                   Robert F. Burnett, Director
                                   Division of Safeguards and Transportation
                                   Office of Nuclear Material Safety
                                     and Safeguards

Technical Contact:  A. W. Grella, NMSS
                    (301) 427-4709

Attachment:  List of Recently Issued NRC Information Notices