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").
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