Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSIN No.: 6835
Accession No.:
8107230047
IN 80-32, Rev. 1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
February 12, 1982
Information Notice No. 80-32 Rev. 1: CLARIFICATION OF CERTAIN
REQUIREMENTS FOR EXCLUSIVE-USE
SHIPMENTS OF RADIOACTIVE
MATERIALS
This is a supplement to Information Notice No. 80-32, originally issued
August 29, 1980. It is intended to clarify Question/Answer Numbers 1, 5 and
6 and Appendices A and B on which there have been numerous questions and
inquiries. Those paragraphs and appendices are superceded as follows:
1. Q. What radiation limits would apply to shipments being transported
on an open exclusive-use transport vehicle?
A. The constraints of 49 CFR SS173.393(j)(3) and (4) would apply;
e.g., 10 mrem/hr at 2 meters from the open planes projected by the
outer lateral edges of the vehicle, and 2 mrem/hr in any normally
occupied area of the vehicle (cab).
Note: As a matter of clarification, it is important to point out
that, in its queries to the Department of Transportation
(DOT) on the correct interpretation of SS173.393(i) and (j),
NRC has been advised that the existing language of
SS173.393(j) does not clearly reflect the original intent of
the regulation; i.e., to limit the radiation level at the
accessible exterior surface of a package on an open
exclusive-use vehicle to 200 mrem/hr (such as the same limit
applied to the surface of a closed transport vehicle). DOT
has stated that it is currently taking steps to revise
SS173.393(j). In the interim, NRC licensees are urged and
cautioned to adhere to a surface radiation level limit of 200
mrem/hr on a package transported on an open exclusive-use
transport vehicle, as has been the practice and
interpretation of most shippers in the past.
5. Q. If "packages," such as secondary inner drums, (as contrasted to a
simple personnel barrier as discussed in Q.4 above), are enclosed
within an outer shield, may this shield be considered to be an
integral part of the "closed transport vehicle" when such a shield
provides attenuation of the vehicle radiation levels to meet the
200 mrem/hr limit of SS173.393(j)(2)? Further, what other
considerations are there in such a situation in determining what
constitutes the "package" as opposed to the "vehicle"?
A. This question of defining what constitutes the "package" has
arisen frequently and has created much confusion. Generally
speaking, the criteria to be considered, which are illustrated in
Appendix B, include the following factors:
.
IN 80-32, Rev. 1
February 12, 1982
Page 2 of 2
o Whether or not any single inner container, e.g., drum has a
radiation level of less than l rem/hr at 3 feet [SS173.393(j)(1)]
o Whether or not any single inner container, if bearing LSA
material, has a quantity of radioactivity exceeding Type A [SS10
CFR 71.7(b), 71.11(b)(1), 71.12(b) and 71.35].
Given the above considerations and the DOT definitions of "closed
transport vehicle" [SS173.389(q)] and "packaging" (SS171 8), each inner
drum within an outer shield integrally attached to the vehicle may be
considered a provided that each inner drum compiles with
SS173.393(j)(1), (1 rem/hr at 3 ft) and also provided that the content
within any single inner drum does not exceed a Type A quantity of LSA
material. In this configuration, the outer enclosure may be considered
as the closed transport vehicle and may incorporate integral shielding
to meet the vehicle limit of SS173.393(j)(2) (200 mrem/hr). The inner
drums would be marked as packages and the outer enclosure placarded as
a vehicle.
6. Q. In contrast, under what circumstances would the outer enclosure
plus its secondary inner containers, taken together, be considered
as the "package"?
A. The combination of inner containers plus the outer shield are
considered the "package" if any single inner container has a
quantity of radioactivity as LSA exceeding Type A or if any single
inner container exceeds the limit of SS173.393(j)(1) [1-rem/hr at
3 ft]. Such "packages" must be certified as Type A by the NRC
Office of Nuclear Materials Safety and Safeguards.
No written response to this notice is required. If you need additional
information regarding this subject, contact the Regional Administrator of
the appropriate NRC Regional Office.
Attachments:
1. Appendices A and B
2. Recently issued Information Notice No.
