Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSINS No.: 6835
IN 87-31
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D. C. 20555
July 10, 1987
Information Notice No. 87-31: BLOCKING, BRACING, AND SECURING OF RADIO-
ACTIVE MATERIALS PACKAGES IN TRANSPORTATION
Addressees:
All NRC licensees.
Purpose:
This notice is provided to remind licensees of their responsibilities to
ensure the proper blocking, bracing, and securing (tie-down) of radioactive
materials packages being offered to a carrier, wherein transport by
exclusive-use vehicle is required, or packages being transported by the
licensee as a private carrier, whether by an exclusive-use or a
non-exclusive-use vehicle.
It is suggested that licensees review this information for applicability to
their shipping and transportation program and consider actions, if
appropriate, to preclude similar problems with their shipments. However,
suggestions contained in this notice do not constitute NRC requirements;
therefore, no specific action or written response is required.
Description of Circumstances:
There has been evidence of inadequacies in the blocking, bracing, and securing
of packages to the transport vehicle involving packaged shipments of low-
specific-activity (LSA) radioactive material (radwaste) in drums or bins. The
following are recent, typical examples of such inadequacies:
On April 25, 1986, an exclusive-use shipment of LSA waste from a nuclear
power plant in the Midwest arrived at the Barnwell, South Carolina waste
disposal site. The inspector for the State of South Carolina who was at
the site observed that the three packages on the flatbed trailer had
shifted in transit as a result of inadequate blocking and bracing.
On July 7, 1986, a nuclear fuel plant in the southeast made a shipment of
two 10-ton uranium hexafluoride cylinders to the gaseous diffusion plant
at Paducah, Kentucky. After departure, one cylinder broke free and fell
from the vehicle onto the ground when the truck made a sudden stop. Con-
tributing causes of the load separation were a faulty hold-down strap
and inadequate bracing and tie-down of the cylinder and cylinder
supports.
8707060140
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On June 5, 1986, an exclusive-use shipment of LSA waste from a nuclear
plant in the South arrived at the Barnwell waste disposal site. When the
State of South Carolina inspector at the site opened the closed trailer,
he observed that the blocking and bracing that had been provided was
inadequate to prevent the movement of some drums during transit.
In each of these instances, enforcement action was taken against the shipper
for failure to comply with the Department of Transportation (DOT) regulations.
Discussion:
Section 10 CFR 71.5(a) requires that each licensee who transports licensed
material outside of the confines of its plant or place of use or who delivers
licensed material to a carrier for transport, shall comply with the applicable
requirements of the DOT in 49 CFR Parts 170-189 for the mode of transport
used. These requirements apply whether the mode of transport is by rail, air,
water, or public highway.
Many packages offered for transport by licensees, including waste shipments,
qualify as LSA as defined in 49 CFR 173.403(n). When packaged LSA materials
are shipped by exclusive-use vehicles, the requirements in 40 CFR 173.425(b)
must be met.
In addition to the limits for external radiation levels and removable
contamination, the other requirements of 49 CFR 173.425(b) should be
recognized by all licensees. Specifically, 49 CFR 173.425(b)(4) requires that
the shipment must be loaded by the consignor (e.g., the licensee shipper) and
unloaded by the consignee. Section 49 CFR 173.425(b)(6) requires that the
shipment must be braced to prevent shifting under normal transportation
conditions. Bracing of loads may involve blocking, shoring, tie-downs (chains
and/or straps), or other restraints.
For all shipments of radioactive material requiring an exclusive-use vehicle,
the licensee-shipper is responsible for assuring that the shipment is properly
loaded and secured; it is not the responsibility of the driver or carrier
company. In other words, in such cases, the shipper is assigned the responsi-
bility for certain functions that are normally (for non-exclusive-use
shipments) the responsibility of the carrier. Section 49 CFR 173.403(i),
states that "all initial, intermediate, and final loading and unloading are to
be carried out in accordance with the directions of the consignor or
consignee." Blocking, bracing, and tie-downs, therefore, are considered to be
a part of the loading process and the responsibility of the
consignor-shipper-licensee for exclusive-use shipments. If a load shifts
during normal transport, the licensee bears the responsibility and may be
subject to enforcement actions under 10 CFR 2 when violations occur. In some
cases, the carrier may perform inspections of tie-down provisions during
transport. The applicable instruction provided by the shipper to the carrier
for maintenance of exclusive-use shipment control may provide guidance on this
subject.
Pursuant to 49 CFR 177.842(d), radioactive materials packages must be blocked
and braced such that they cannot change position during conditions normally
incident to transportation. This requirement applies to common or contract
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(i.e., "for-hire" carriers) and private carriers. Therefore, whether or not
the shipment is by exclusive-use vehicle, the requirement applies to licensees
that are transporting packages and acting as both a shipper and a private
carrier; e.g., radiographers, well logging companies, radiopharmacy suppliers,
waste brokers, etc.
For shipments offered by a licensee-shipper to a common carrier; e.g., partial
loads in a vehicle that is not for exclusive-use, the carrier is ultimately
responsible for the proper blocking, bracing, and securing of the package.
All too frequently, incidents occur wherein packages are thrown onto the
roadway and lost because of the carrier's failure to properly secure the load
and/or failure to secure the cargo door. In such cases, the carrier may be
subject to enforcement actions by the DOT or a State regulatory authority.
Actions taken by licensees to ensure that shipments are properly loaded and
braced have included written loading procedures with detailed checklists and
quality control oversight and release requirements. When a licensee ships
several types of packages, detailed procedures with a checklist have been
prepared for each. The applicable certificate-of-compliance for an NRC-
certified package may sometimes contain prescriptions for package tie-down
arrangements.
Specific regulatory and technical standards for tie-down of packages to
transport vehicles may be found in:
.49 CFR 393.100, 393.102, and 393.104 - for motor vehicles;
.10 CFR 71.45(b) - applicable to tie-down attachment points that are
structural components of radioactive packages that are subject to the
Package Approval Standards of Subpart E of 10 CFR 71;
ANSI N-14.2 - Proposed American National Standard "Tie-down for Truck
Transport of Radioactive Materials" (currently in the form of Draft 5,
Revision 2, September 2, 1986, and available from the Secretary, N14
Committee, International Energy Associates Limited, 3211 Jermantown Road,
Fairfax, Virginia 22030).
No written response to this information notice is required. If you have any
questions regarding this matter, please contact the Regional Administrator of
the appropriate NRC regional office or this office.
Robert F. Burnett, Director
Division of Safeguards and Transportation
Office of Nuclear Material Safety
and Safeguards
Technical Contact: A. W. Grella, NMSS
(301) 427-4709
Attachment: List of Recently Issued NRC Information Notices