Packing Greater Than Type A Quantities of LSA Radioactive Material for Transport

HPPOS-080 PDR-9111210216

See IE Circular No. 78.03 entitled as above and dated May 12, 1978.

This circular describes a situation at nuclear power facilities that could occur wherever greater than Type A quantities of low specific activity (LSA radioactive materials are packaged for transport. Shipment of greater than Type A quantities of LSA material may be done only in packages certified by NRC under 10 CFR Part 71.

Department of Transportation (DOT) regulations require "strong, tight packages" for LSA material and make no mention of total activity that may be shipped. Some licensees subject to the requirements of 10 CFR Part 71 have shipped packages containing greater than Type A quantities of LSA material in packages which are not authorized by NRC. These unauthorized shipments have resulted from an inadequate understanding of Part 71 regarding LSA material. Differences between Part 71 and DOT requirements in 49 CFR Parts 170 to 189 have apparently contributed to these misunderstandings.

Specifically, 49 CFR 173.392 authorizes the shipment of LSA material in "strong, tight packages" when transported in vehicles assigned for the sole use of the consignor. DOT regulations make no mention of the total activity that may be shipped in this manner. On the other hand, NRC regulations (10 CFR 71.3) require that no licensee shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed material except as authorized in a general or specific license issued by the NRC, or as exempted in Part 71. The general license of 10 CFR 71.12 has requirements for the type of container when more than a Type A quantity of radioactive material is to be transported. LSA material in excess of a Type A quantity is not exempt from the general license requirements.

Several Licensees have failed to recognize the difference between the DOT and NRC requirements and have packaged greater than Type A quantities of LSA material for transport in containers other than those authorized by the general license of 10 CFR 71.12. Compliance with Part 71 is the responsibility of the NRC licensee who delivers licensed material to a carrier for transport or who transports such materials outside the confines of its plant or other place of use.

Regulatory references: 10 CFR 71.2, 49 CFR 173

Subject codes: 12.17

Applicability: All

Page Last Reviewed/Updated Friday, October 13, 2017