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
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
December 31, 1990
Information Notice No. 90-82: REQUIREMENTS FOR USE OF NUCLEAR
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,
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
December 31, 1990
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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:
December 31, 1990
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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
Technical Contact: Earl P. Easton, NMSS
Attachment: List of Recently Issued NMSS Information Notices
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