Information Notice No. 90-82: Requirements For use of Nuclear Regulatory Commission-(NRC-) Approved Transport Packages for Shipment of Type A Quantities of Radioactive Material

                                UNITED STATES
                              WASHINGTON, D.C.
                              December 31, 1990
Information Notice No. 90-82:  REQUIREMENTS FOR USE OF NUCLEAR 
                                   REGULATORY COMMISSION-(NRC-)APPROVED 
                                   TRANSPORT PACKAGES FOR SHIPMENT OF TYPE A 
                                   QUANTITIES OF RADIOACTIVE MATERIAL
All registered users of NRC-approved packages.
This notice is to inform registered users of NRC-approved packages of 
pertinent NRC and Department of Transportation (DOT) requirements for the 
use of NRC-approved Type B packages for shipment of Type A quantities of 
radioactive materials.  This notice applies to levels of radioactive 
materials that are not required to be shipped in an NRC-approved package, 
under the exemption granted in 10 CFR 71.10.
It is expected that registered users of NRC packages will review this 
information for applicability to their shipping and transportation programs 
and consider actions, as appropriate, to avoid problems in transport of 
radioactive materials.  However, suggestions contained in this information 
notice do not constitute any new requirements; therefore, no specific action 
or written response is required.  In addition, no specific written response 
is required by DOT.
Description of Circumstances:
On March 8, 1990, Amersham Corporation (Amersham), Burlington, 
Massachusetts, an NRC licensee authorized to manufacture and distribute 
sealed sources for use in industrial radiography, received an "empty"  Model 
No. 500 SU source changer from its Korean product distributor.  Amersham 
subsequently discovered that the source changer was not empty, but contained 
a 2.4-curie cropped source in the unshielded portion of the source changer.  
The incident was investigated by an NRC incident investigation team and the 
results reported in NUREG-1405 (published in May 1990), "Inadvertent 
Shipment of a Radiographic Source from Korea to Amersham Corporation, 
Burlington, Massachusetts." 
During the investigation, it became apparent that clarification concerning 
the use of NRC-approved Type B packages for shipment of Type A quantities of 
radioactive materials was needed.  Since the special form iridium-192 source 
involved in the incident was 2.4 curies, it was exempted under 10 CFR 71.10 
from the requirement that it be shipped in an NRC-approved package.  
However, DOT regulations (49 CFR 173.415) authorize the use of NRC-certified 
Type B packages, such as the Model No. 500 SU, to ship Type A quantities of 
radioactive materials. 
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NRC and DOT share primary responsibility for approving package designs for 
transportation of radioactive materials within the United States.  NRC 
regulations for the transportation of radioactive materials are codified in 
10 CFR Part 71, "Packaging and Transportation of Radioactive Material."  
DOT's hazardous materials regulations, which include radioactive material, 
are codified in 49 CFR Parts 100-199.  Requirements for shippers of 
radioactive materials are given in 49 CFR 173.400 through 173.478.  In 
addition, a provision in the NRC regulations, 10 CFR 71.5, requires that NRC 
licensees comply with DOT's hazardous materials regulations. 
In general, pursuant to 10 CFR Part 71, NRC approves package designs for 
shipment of fissile and greater than Type A quantities of radioactive 
material.  The design for packages up to Type A quantities is subject to the 
requirements of DOT in 49 CFR Part 173.  
In authorizing the use of NRC-approved packages for transportation of Type A 
quantities of radioactive material, DOT regulations specify, in 49 CFR 
173.415, that certain conditions be met.  One condition (49 CFR 173.471) is 
that the shipment of the package be made in compliance with the terms of the 
NRC approval, i.e., that the shipper comply with all terms and conditions in 
the NRC certificate of compliance (certificate).  For example, a 
radiographic source changer authorized for a Type B quantity of a specific 
radionuclide in special form is also authorized for a Type A quantity of the 
same specific radionuclide in special form, provided that all the terms and 
conditions of the certificate are met.  Note that NRC approvals include the 
type and form of material, the maximum quantity of material per package, and 
operating instructions and maintenance procedures for the package.  
Alternatively, an NRC-approved package may be shipped under the provisions 
of 49 CFR 173.415(a), as a DOT Specification 7A package.  In this instance, 
the shipper (if requested) must provide DOT with a complete documentation of 
tests and an engineering evaluation or comparative data showing that the 
construction methods, packaging design, and materials of construction comply 
with DOT Specification 7A.  The shipper is required to maintain this 
documentation on file at least 1 year after the latest shipment.  Thus, a 
radiographic source changer approved by NRC for shipment of a specific 
radionuclide in special form could be used to ship a Type A quantity of a 
different nuclide, provided that the package is re-evaluated under the 
provisions of 49 CFR 173.415(a).    
When an NRC-approved package is used as a DOT Specification 7A package, the 
NRC package identification marking should be covered and new markings ("USA 
DOT 7A TYPE A" and "radioactive material") affixed to the package, pursuant 
to 49 CFR173.415(a). 
Users of the NRC-approved packages should be aware of the requirements for 
using NRC-approved packages for low-level radioactive materials exempted 
under 10 CFR 71.10.  In particular, users of NRC-approved packages should:
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1.   Determine what provision of 49 CFR 173.415 applies.
2.   When the shipment is made pursuant to 49 CFR 173.415(a), comply with 
     all requirements in 49 CFR 173.415(a) and 49 CFR 178.350.  Note that 
     the use of an NRC-approved package pursuant to 49 CFR 173.415(a) 
     requires that the package be re-evaluated as a DOT Specification 7A 
     Type A package, and that the shipper maintain the evaluation on file 
     for 1 year after the last shipment.
3.   When the shipment is made pursuant to 49 CFR 173.415(c), comply with 
     all terms and conditions in the NRC certificate. 
No written response is required by this information notice.  If you have any 
questions about this matter, please contact the appropriate NRC regional 
office, or this office.  Questions concerning DOT requirements should be 
directed to the Radioactive Materials Branch, Office of Hazardous Materials 
Technology, DOT (202) 366-4545.
                         Robert F. Burnett, Director
                         Division of Safeguards and Transportation
                         Office of Nuclear Material Safety
                           and Safeguards
Technical Contact: Earl P. Easton, NMSS
                  (301) 492-0462
Attachment:  List of Recently Issued NMSS Information Notices

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