Information Notice No. 87-47:Transportation of Radiography Devices (Update of Information Notice No. 81-02, January 23, 1981)

                                                 SSINS No.: 6835 
                                                    IN 87-47 


                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
                              WASHINGTON, DC  20555

                                 October 5, 1987


Information Notice No. 87-47:  TRANSPORTATION OF RADIOGRAPHY DEVICES 
                                   (Update of Information Notice No. 81-02,
                                   January 23, 1981)

Addressees:  

All NRC licensees authorized to manufacture, distribute and/or operate radio-
graphic exposure devices and/or source changers. 

Purpose: 

This notice is provided to remind licensees of the pertinent transportation 
requirements for radiography devices when used as transport "packages."  The 
following explanations should help to clarify the application of operational 
licensing requirements versus transport requirements applicable to shippers 
and carriers, thereby prompting improved regulatory compliance with these 
requirements.  Requirements for a license are attached.

It is suggested that licensees review this information for applicability to 
their operations involving transportation of radiography devices, and consider 
actions, if appropriate, to preclude violations of the transport regulatory 
requirements.  However, suggestions contained in this notice do not constitute 
NRC requirements; therefore, no specific action or written response is 
required.

Description of Circumstances:

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 U.S. Department of 
Transportation (DOT) regulatory requirements in 49 CFR 170-189 as direct NRC 
requirements (see 10 CFR 71.5). 

The nature of radiography operations is 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 






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caused some confusion for radiography users, particularly with respect to 
sorting out the transport regulatory requirements of DOT/NRC from the opera-
tional requirements of 10 CFR 34 and the specific license which has been 
issued to the user of radiography devices.  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.

Discussion:  

Source Design -- Radiography sources contained within a device are always 
encapsulated radioactive material (Co-60 or Ir-192).  They should meet the 
physical integrity requirements of "special form," as defined in 49 CFR 
173.403(z) and 10 CFR 71.4.  Radiography transporters are reminded that 
requirements in 49 CFR 173.476(a) 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 design to 
demonstrate that it meets the special form requirements.  This does not mean 
that each shipper has to actually perform the tests, only that the shipper 
obtain and retain the documentation of the tests.  As a practical matter, each 
radiographer should establish a file of such data for each source design that 
is used.  It may be necessary, therefore, for the radiographer to request the 
required information from the source manufacturer/supplier.

Package Design -- Radiography sources in special form will constitute a Type B
quantity of radioactive material, with Type B packaging required for 
transportation purposes, when the activity is in excess of a A1*curies (A1Ci).

Issuance of an NRC Certificate of Compliance is a necessary prerequisite to 
the use of a radiography device containing a special form source that exceeds 
A1 curies.  For those radiography devices that exceed A1 activity, an NRC 
Certificate of Compliance (COC) must be issued, as required by 10 CFR 71.12 
and 49 CFR 173.416(b).  Such approved devices may be used by other than the 
original COC applicant, provided that such user registers with the NRC Office 
of Nuclear Material Safety and Safeguards (NMSS), has a copy of the applicable 
COC, and complies with its terms and conditions (see 10 CFR 71.12).  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 report, "Directory 
of Certificates of Compliance for Radioactive Materials Packages" 
(NUREG-0383), which is updated annually.  (Devices which were manufactured to 
the now obsolete DOT Spec. 55 are no longer authorized for transportation 
unless enclosed in a DOT specification overpack.  See specification overpacks 
below.)

____________________
*A1 = maximum activity permitted in a Type A package when the material is in 
 "special form."  For Ir-192, A1 = 20 Curie; for Co-60, A1 = 7 Curie (defined 
 in 49 CFR 173.403(a) and 10 CFR 71.4.  There are tables of A1/A2 values for 
 radionuclides in 49 CFR 173.435 and in 10 CFR 71, Appendix A).
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CAUTION:  The fact that the use of 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 NRC has approved it as a 
          Type B transport package pursuant to 10 CFR Part 71.

For international shipments, shippers must additionally register with DOT as 
users of the DOT Certificate of Competent National Authority pursuant to 
49 CFR 173.472.  DOT further requires that this certificate be supplied to the 
foreign consignee and Competent National Authority of the destination country 
and other countries through which the package will be transported.  

Specification Overpacks -- Pursuant to 49 CFR 173.416(f) or (g), DOT Spec. 55 
packages may be used to transport quantities of activity exceeding A1Ci of 
special form radioactive material provided that a Spec. 20 WC (49 CFR 178.194) 
or Spec. 21 WC (49 CFR 178.195) protective overpack is used.  However, this 
authorization is restricted to the use of Spec. 55 packages constructed before
April 31, 1975.  

Type A Packages -- For radiography devices containing special form sources not 
exceeding A1Ci of activity, the authorized packages are stated in 49 CFR 
173.415.  As a practical matter, the DOT Spec. 7A [49 CFR 173.415(a) and 
178.350] is most frequently applicable. DOT regulations require that each 
shipper of a Spec. 7A package maintain on file written documentation showing 
that the construction methods, packaging, design, and material of construction 
comply with that specification [see 49 CFR 173.415(a)].

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 designer/user or to perform and document the tests on 
his own [see 49 CFR 173.415(a) and 173.475].  

Package Labeling -- During transportation each radiography device (package) 
must be properly labelled with the appropriate category of RADIOACTIVE label 
in accordance with 49 CFR 172.403.  This requires affixing two labels on 
opposite sides of the package. The type of label is based on the radiation 
levels at the surface of the package and at 1 meter.  The 1 meter dose rate 
determines the transport index (TI) that is indicated on the label.  
Additionally, the label must contain isotope and activity.  The 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 1 meter from any point on the external surface 
of the package [10 CFR 71.47 and 173.441(a)].

A question frequently arises regarding the labeling of radiography devices 
when enclosed within an outer "convenience" box, enclosure, foot locker, etc., 
during transportation.  The question is whether the radiation levels at the 
surface of such an outer enclosure may be used to establish the labeling 
requirements for 
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the overall "package."  It is permissible to use such enclosures and to estab-
lish labeling on the basis of the radiation levels at the exterior of the 
outer enclosure.  Assuming that the inner component (the device) 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)].  It must also be labeled, as 
required, based on the dose rates at the external surface of the package and 
at 1 meter from the outer enclosure.

CAUTION:  The fact that a particular device has been approved in an NRC COC 
          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 and the appropriate IT is present 
          thereby.

Packages exceeding the limits of 49 CFR 173.441(a) may be transported in a 
closed, exclusive-use vehicle, such as a radiographer's van (but not an open 
pickup truck), provided that the following limits are not exceeded: 

     1,000 mrem/hr on the external surface of the package, 200 mrem/hr at any 
     point on the external surface of the vehicle, and 10 mrem/hr at 2 meters 
     from the lateral surfaces of the vehicle [49 CFR 173.441(b)].

This means that a radiographer may transport a package reading more than 200 
mrem/hr at the surface, but not more than 1000 mrem/hr at the surface, in the 
radiographer's own exclusive-use vehicle [see 49 CFR 173.403(i)].  The radio-
grapher may not deliver the same package to a carrier for transport unless the 
carrier's vehicle has been consigned for the radiographer's exclusive use.  

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 172.202 and 
172.203(d) for radioactive material, including the following: 

1.   The DOT proper shipping name.  (For radiography devices, this will 
     usually be "RADIOACTIVE MATERIAL, SPECIAL FORM N.O.S".)  See 49 CFR 
     172.101.  Also, the hazard identification number for special form is:  
     "UN2974."

     NOTE:  For packages containing a special form source wherein the A1limit 
            equals the A2 limit for the specific nuclide, e.g., Co 60, it is 
            suggested that the DOT proper shipping name and hazard identi-
            fication of "RADIOACTIVE MATERIAL, N.O.S" and "UN2982" be used.  
            This will obviate the necessity to obtain the special form testing 
            documentation.  [See 49 CFR 173.476(c)]

2.   The name of each radionuclide.

3.   A description of the physical and chemical form of the material.  For 
     special form sources, this description is "SPECIAL FORM."  In cases where
     A1= A2 and the special form proper shipping name is not used, a typical 
     radionuclide name and description might be "Cobalt-60 as contained within
     a welded, hermetically sealed stainless steel capsule."

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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 of "cargo aircraft only."  

     NOTE:  No industrial radiography shipments would 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 
     173.441(b).  [See 49 CFR 173.441(c).] 
     
     NOTE:  The repetitive nature of radiography transportation lends itself 
            to the preparation of a "permanent" type of shipping paper docu-
            mentation that is specific to each particular source/device con-
            figuration.  Such documentation could even take the form of 
            laminated cards which are retained and accessible within the 
            vehicle.  [See 49 CFR 177.817(e).]

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 
Part 172.500-172.519, 172.556 and Appendices B and C) if any package bearing 
the RADIOACTIVE YELLOW-III label is to be carried in the vehicle.  For a 
YELLOW-III labeled package tendered to a common motor carrier, the licensee 
must provide the required placards to the carrier at the time the packages are 
picked up, unless the carrier's vehicle is already placarded as required.  

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 have occurred where devices are dropped 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).
(See Information Notice No. 87-31, July 10, 1987.)

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It is suggested that licensees 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 appropriate NRC Regional Office 
or this office.




                              Richard E. Cunningham, Director
                              Division of Industrial and Medical
                                Nuclear Safety
                              Office of Nuclear Material Safety
                                and Safeguards

Technical Contacts: A. W. Grella, NMSS/SGOB
                    (301)427-4709

                    S. Baggett, NMSS/IMAB
                    (301)427-9005

Attachments:
1.  Requirements for a License
2.  List of Radiography Devices and Containers 
    having NRC Certificates of Compliance
3.  List of Recently Issued NRC Information Notices

.                                                            Attachment 1 
                                                            IN 87-47 
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                           REQUIREMENTS FOR A LICENSE


The scope of 10 CFR Part 71, as defined in . 71.0(c) includes all specific 
licensees of the Commission if the licensee delivers radioactive material to a 
carrier for transport or transports the material outside the confines of his 
facility, plant, or other authorized place of use.  This scope includes all 
radiographers licensed under 10 CFR Part 34, including those who conduct 
radiographic operations in the field, those who transport replacement sources, 
or who deliver replacement sources to a carrier for transport. 

Section 71.3 "Requirement for License" in 10 CFR Part 71 prohibits any such 
transport or delivery to a carrier except as authorized in a general license 
or a specific license issued by the Commission, or as exempted in Part 71.  
Specific licenses issued under 10 CFR Part 34 are not intended to satisfy this 
requirement for a license prescribed by . 71.3.  In most cases, the general 
licenses containing .. 71.12, 71.14, and 71.16 of 10 CFR Part 71 are adequate 
to satisfy the requirement for license as applied to radiographers.  Any 
specific license issued to satisfy this requirement would be issued pursuant 
to 10 CFR Part 71. 

The three general licenses in 10 CFR Part 71, in .. 71.12, 71.14, and 71.16, 
have conditions which apply to transportation of radiography devices or source
exchangers.  The user of the Part 71 general license (usually the shipper and 
frequently also the carrier of the radiographic exposure device) must register
as a user of the general license with NRC and must have an approved quality 
assurance program which satisfies the previsions of Part 71, Subpart H (see 
. 71.101, "Quality Assurance Requirements").