**NRC INSPECTION MANUAL** NMSS

INSPECTION PROCEDURE 86740

INSPECTION OF TRANSPORTATION ACTIVITIES

PROGRAM APPLICABILITY: 2500, 2515, 2600, and 2800

TABLE OF CONTENTS

[Page]{.underline}

86740-01 INSPECTION OBJECTIVES [1](#__RefHeading___Toc189653099)

86740-02 INSPECTION REQUIREMENTS [1](#__RefHeading___Toc189653100)

SUBSECTION A BASIC REQUIREMENTS [1](#__RefHeading___Toc189653101)

02.01 Preparation of Packages for Shipment
[1](#__RefHeading___Toc189653102)

a\. Preliminary Determinations [1](#__RefHeading___Toc189653103)

b\. Routine Determinations [1](#__RefHeading___Toc189653104)

c\. Liquid Package Requirements [1](#__RefHeading___Toc189653105)

d\. Packaging Marking [2](#__RefHeading___Toc189653106)

e\. Package Labeling [2](#__RefHeading___Toc189653107)

f\. Radiation Monitoring [2](#__RefHeading___Toc189653108)

02.02 Delivery of Completed Packages to Carriers
[2](#__RefHeading___Toc189653109)

a\. Shipping Paper Documentation [2](#__RefHeading___Toc189653110)

b\. Loading and Placarding Non-Exclusive-Use Shipments
[2](#__RefHeading___Toc189653111)

c\. Loading and Placarding Exclusive-Use Shipments
[2](#__RefHeading___Toc189653112)

d\. HAZMAT Employee Training [3](#__RefHeading___Toc189653113)

02.03 Receipt of Packages [3](#__RefHeading___Toc189653114)

02.04 Records and Reports [3](#__RefHeading___Toc189653115)

a\. DOT Specification 7A Type A Packaging
[3](#__RefHeading___Toc189653116)

b\. Special Form Documentation [3](#__RefHeading___Toc189653117)

c\. Incident Reporting [3](#__RefHeading___Toc189653118)

SUBSECTION B ADDITIONAL REQUIREMENTS [3](#__RefHeading___Toc189653119)

02.05 General License Requirements [3](#__RefHeading___Toc189653120)

02.06 Management Controls [4](#__RefHeading___Toc189653121)

02.07 Indoctrination and Training Program
[4](#__RefHeading___Toc189653122)

02.08 Quality Assurance Program [4](#__RefHeading___Toc189653123)

02.09 Audit Program [4](#__RefHeading___Toc189653124)

02.10 Procurement and Selection of Packagings
[5](#__RefHeading___Toc189653125)

a\. Fabrication of Packagings [5](#__RefHeading___Toc189653126)

b\. DOT Revalidation of Foreign-Approved Packagings
[5](#__RefHeading___Toc189653127)

02.11 Preparation of Packages for Shipment
[5](#__RefHeading___Toc189653128)

a\. Package Marking [5](#__RefHeading___Toc189653129)

b\. Advance Notification to Consignee [5](#__RefHeading___Toc189653130)

c\. Advance Notification to States [5](#__RefHeading___Toc189653131)

02.12 Periodic Maintenance of Packagings
[5](#__RefHeading___Toc189653132)

02.13 Records, Reports, and Notifications
[6](#__RefHeading___Toc189653133)

a\. Record of Shipment [6](#__RefHeading___Toc189653134)

b\. Quality Assurance Records - Components and Services
[6](#__RefHeading___Toc189653135)

c\. Quality Assurance Records - Other [6](#__RefHeading___Toc189653136)

d\. Notification of Excess Contamination or Radiation Level
[6](#__RefHeading___Toc189653137)

e\. Reduction in Package Effectiveness Report
[6](#__RefHeading___Toc189653138)

86740-03 INSPECTION GUIDANCE [6](#__RefHeading___Toc189653139)

03.01 General Guidance [6](#__RefHeading___Toc189653140)

03.02 Specific Guidance [7](#__RefHeading___Toc189653141)

SUBSECTION A GUIDANCE FOR BASIC REQUIREMENTS
[7](#__RefHeading___Toc189653142)

a\. Inspection Requirement 02.01(c) [7](#__RefHeading___Toc189653143)

b\. Inspection Requirement 02.01(d) [7](#__RefHeading___Toc189653144)

c\. Inspection Requirement 02.01(e) [8](#__RefHeading___Toc189653145)

d\. Inspection Requirement 02.01(f) [9](#__RefHeading___Toc189653146)

e\. Inspection Requirement 02.02(a) [10](#__RefHeading___Toc189653147)

f\. Inspection Requirement 02.02(b) [12](#__RefHeading___Toc189653148)

g\. Inspection Requirement 02.03 [12](#__RefHeading___Toc189653149)

h\. Inspection Requirement 02.04(a) [12](#__RefHeading___Toc189653150)

i\. Inspection Requirement 02.04(b) [13](#__RefHeading___Toc189653151)

SUBSECTION B GUIDANCE FOR ADDITIONAL REQUIREMENTS
[13](#__RefHeading___Toc189653152)

j\. Inspection Requirement 02.06 [13](#__RefHeading___Toc189653153)

k\. Inspection Requirement 02.08 [14](#__RefHeading___Toc189653154)

l\. Inspection Requirement 02.10(a)-(b)
[14](#__RefHeading___Toc189653155)

m\. Inspection Requirement 02.11(a) [15](#__RefHeading___Toc189653156)

n\. Inspection Requirement 02.11(b) [16](#__RefHeading___Toc189653157)

o\. Inspection Requirement 02.11 [16](#__RefHeading___Toc189653158)

86740-04 RESOURCE ESTIMATE [16](#__RefHeading___Toc189653159)

86740-05 REFERENCES [16](#__RefHeading___Toc189653160)

05.01 Regulations [16](#__RefHeading___Toc189653161)

05.02 NRC Information Notices [16](#__RefHeading___Toc189653162)

05.03 NRC Regulatory Guides [19](#__RefHeading___Toc189653163)

05.04 Other Publications [20](#__RefHeading___Toc189653164)

ATTACHMENT 1 Revision History for IP 86740
Att1-[1](#__RefHeading___Toc189653165)

86740-01 INSPECTION OBJECTIVES[]{#__RefHeading___Toc189653099 .anchor}

To determine whether the licensee has established and is maintaining an
effective management-controlled program, to ensure radiological and
nuclear safety in the receipt, packaging, delivery to a carrier and, as
applicable, the private carriage of licensed radioactive materials; and
to determine whether transporta­tion activities are in compliance with
the applicable Nuclear Regulatory Commission (10 CFR Parts 20 and 71)
and Department of Transportation (DOT) (49 CFR Parts 171-178) transport
regulations.

This inspection procedure is organized into two sections: Section 1
covers basic transportation requirements found in 10 CFR (Code of
Federal Regulations) Part 20, 10 CFR Part 71, Subpart A, and 49 CFR
Parts 171-177. Section 2 covers additional transportation requirements
found in 10 CFR Part 71, Subparts C, G, and H, and corresponding parts
of 49 CFR.

Use Section 1 to inspect all licensees. Determine whether the licensee
meets the exemption criteria in 10 CFR Part 71 Subpart B. If the
licensee meets the exemption criteria, the inspection may be concluded
after conducting Section 1; Section 2 does not apply. If the licensee
does not meet the exemption criteria, use both Sections 1 and 2 to
conduct the inspection.

86740-02 INSPECTION REQUIREMENTS[]{#__RefHeading___Toc189653100 .anchor}

[SUBSECTION A BASIC
REQUIREMENTS]{.underline}.[]{#__RefHeading___Toc189653101 .anchor}

02.01 [Preparation of Packages for
Shipment]{.underline}.[]{#__RefHeading___Toc189653102 .anchor} Examine
the licensee's written procedures and shipment records. As the situation
allows, observe actual package preparations and operations so as to:

a\. [Preliminary
Determinations]{.underline}.[]{#__RefHeading___Toc189653103 .anchor}
Verify that before the [initial]{.underline} use of any packaging, the
licensee performs the required [preliminary]{.underline} determinations
and quality control relating to construction of the packaging (49 CFR
173.474).

b\. [Routine Determinations]{.underline}.[]{#__RefHeading___Toc189653104
.anchor} Verify that before [each]{.underline} use of any packaging the
licensee performs the required [routine]{.underline} determinations and
quality control (49 CFR 173.475 and 10 CFR 71.87).

c\. [Liquid Package
Requirements]{.underline}.[]{#__RefHeading___Toc189653105 .anchor}

1\. Verify that for non-low specific-activity (LSA) Type A packages with
liquid contents, the licensee has provided for the required special
testing, double containment system, and absorbent material, as
appropriate \[49 CFR 173.412(k)\].

2\. Verify that when required for packages containing liquid contents
exceeding a Type A quantity and destined for air shipment, a test for
leakage is performed on the containment system \[49 CFR 173.475(g)\].

d\. [Packaging Marking]{.underline}.[]{#__RefHeading___Toc189653106
.anchor} Verify that the licensee has marked the package with the
applicable general and specific package markings that are required (49
CFR 172.300 - 310). Note that 49 CFR 172.324 addresses reportable
quantity (RQ) markings on packages).

e\. [Package Labeling]{.underline}.[]{#__RefHeading___Toc189653107
.anchor} Verify that for non-exempted packages, the licensee provides
for and accomplishes labeling of each package with the appropriate
category of RADIOACTIVE (White-I, Yellow-II, or Yellow-III) label, one
each on two opposite sides of the package; and accurately completes the
entry of the required information in the blank spaces thereon (49 CFR
172, Subpart E).

f\. [Radiation Monitoring]{.underline}.[]{#__RefHeading___Toc189653108
.anchor} Verify that the licensee provides for and accomplishes
monitoring of each completed package, to ensure that external radiation
and removable surface contamination are within the allowable limits \[49
CFR 173.441, 49 CFR 173.443, 49 CFR 173.475(i), and 10 CFR 71.87(i) and
(j)\].

02.02 [Delivery of Completed Packages to
Carriers]{.underline}.[]{#__RefHeading___Toc189653109 .anchor} Examine
the licensee's written procedures, shipment records, and as the
situation allows, observe actual transport operations.

a\. [Shipping Paper
Documentation]{.underline}.[]{#__RefHeading___Toc189653110 .anchor}
Verify whether the licensee prepared the required shipping paper
documentation, and accurately included all the applicable required
elements of information, including the shipper's certificate. \[NOTE:
for licensee private motor vehicle shipments, the certificate is not
required (49 CFR 172.204(b))\].

In the case of low-level solid radwaste shipments to licensed land
burial sites (10 CFR Part 61), verify that the shipping paper
documentation also includes the required additional "waste manifest"
information (Appendix G, 10 CFR Part 20).

b\. [Loading and Placarding Non-Exclusive-Use
Shipments]{.underline}.[]{#__RefHeading___Toc189653111 .anchor} Verify
that the licensee provides to a highway carrier, or applies directly to
a rail vehicle, the required placards, whenever the licensee delivers
any quantity of RADIOACTIVE-Yellow-III labeled packages to such carrier
for transport (49 CFR 172.506 and 508).

> c\. [Loading and Placarding Exclusive-Use
> Shipments]{.underline}.[]{#__RefHeading___Toc189653112 .anchor}

1\. Verify that the licensee ensures that the package and vehicle
radiation/contamination levels are within the regulatory limits (49 CFR
173.441 and 443).

2\. Verify that, except for uranium or thorium ores, the transport
vehicle is placarded by the licensee when delivering to a carrier any
exclusive-use shipment for which placarding is required \[49 CFR Part
172, Subpart F, and 49 CFR 173.427(a)(6)(v)\].

3\. Verify that shipping paper documentation provided by the licensee to
the carrier contains satisfactory instructions for maintenance of
exclusive-use shipment controls \[49 CFR 173.441(c) and (e) and 49 CFR
173.427(a)(6)(iv)\].

4\. Verify that for exclusive-use shipments of LSA materials, the
licensee has provided for the additional specific requirements \[49 CFR
173.427(a), (b), or (c)\].

d\. [HAZMAT (Hazardous Material) Employee
Training]{.underline}.[]{#__RefHeading___Toc189653113 .anchor} Verify
that persons involved in the packaging preparation and transport have
received proper and adequate training, and that this training has been
appropriately documented \[49 CFR 172.700 - 704\].

02.03 [Receipt of Packages]{.underline}.[]{#__RefHeading___Toc189653114
.anchor} Examine the licensee's procedures and records of incoming
shipments to verify compliance with the applicable requirements relating
to pickup from a carrier, receiving, and safe opening of packages (10
CFR 20.1906).

02.04 [Records and Reports]{.underline}.[]{#__RefHeading___Toc189653115
.anchor} Review licensee's records and procedures for recordkeeping and
reports to verify that a system is in place to:

a\. [DOT Specification 7A Type A
Packaging]{.underline}.[]{#__RefHeading___Toc189653116 .anchor}
Maintain, on file, for at least one year after shipment, the
documentation of DOT Spec. 7A safety analysis/testing and/or special
form testing \[49 CFR 173.415(a), 49 CFR 173.469, and 49 CFR 173.476\].

b\. [Special Form
Documentation]{.underline}.[]{#__RefHeading___Toc189653117 .anchor}
Verify that for packages where the licensee relies on a special form
determination, to qualify the package as either a limited or Type A
quantity, the licensee maintains on file, for at least one year after
any shipment, and provides, on request, the documentation demonstrating
that the special form material meets the applicable test requirements
(49 CFR 173.469 and 173.476).

c\. [Incident Reporting]{.underline}.[]{#__RefHeading___Toc189653118
.anchor} Immediately report to DOT, when transporting licensed material
as a private carrier, any incident that occurs in which, as a direct
result of the radioactive material, any person is killed, receives
injuries requiring hospitalization; property damage exceeds \$50,000; or
fire, breakage, spillage, or suspected radioactive contamination occurs
(49 CFR 171.15 and 49 CFR 171.16).

[SUBSECTION B ADDITIONAL
REQUIREMENTS]{.underline}.[]{#__RefHeading___Toc189653119 .anchor}

02.05 [General License
Requirements]{.underline}.[]{#__RefHeading___Toc189653120 .anchor}
Determine which general license(s) in 10 CFR Part 71, Subpart C, the
licensee uses to ship radioactive material packages (e.g., 10 CFR 71.17,
71.19, 71,20, 71.21 and 71.22, etc.). Verify that:

a\. The licensee has copies of the specific license, NRC (Nuclear
Regulatory Commission) Certificate of Compliance (COC), DOT
specification, or other approval of the package.

b\. If shipping NRC-certified package(s), has registered with NRC as a
user of NRC‑certified package(s).

c\. Complies with 10 CFR Part 71, Subparts A, G, and H, as applicable.

d\. Has a quality assurance (QA) program approval issued by the
Commission, as applicable.

e\. Complies with other requirements specific to the general license(s)
used.

02.06 [Management Controls]{.underline}.[]{#__RefHeading___Toc189653121
.anchor} Review the system of management controls for transportation
activities and verify that:

a\. Transportation authorities and responsibilities are delineated among
individuals and/or organizational entities, and designated in writing.

b\. Written management-approved instructions have been established to
carry out the various transportation activities, including authorized
changes.

02.07 [Indoctrination and Training
Program]{.underline}.[]{#__RefHeading___Toc189653122 .anchor} Verify
implementation of the indoctrination and training program for persons
involved in the licensee's transport activities:

a\. Discuss the program with the licensee's representative charged with
the responsibility for the training. Identify the major elements of the
program: the basis used for selection of personnel to be trained; the
schedules and performance of training; and methods used to ensure
qualification of competence; and methods to keep people informed of
changes in procedures and requirements.

b\. Examine records of training completion for all employees involved in
transport activities.

c\. Discuss the training with one or two supervisors and one to five
employees, selected at random, to verify their participation in the
training program. In addition to discussions, inspectors may review
licensee shipping records, and observe licensee activities to check
supervision and/or employee knowledge of licensee‑related specific
procedural requirements.

02.08 [Quality Assurance
Program]{.underline}.[]{#__RefHeading___Toc189653123 .anchor} Review the
licensee's documented QA program, to ensure that the licensee has
fulfilled all commitments made in the licensee's QA program application,
including development of written QA procedures for transporting
radioactive material.

02.09 [Audit Program]{.underline}.[]{#__RefHeading___Toc189653124
.anchor} (10 CFR 71.137). Review the report of the most recent audit of
transport activities conducted by the licensee and, if possible, discuss
the audit program with one to five employees, selected at random, to
check their degree of knowledge of the program and to aid in ensuring
that the licensee is conducting an adequate program. Employee knowledge
may also be evaluated by review of shipping records and directly
observing transportation activities. Verify whether:

a\. The most recent audit was conducted in accordance with the
licensee's published procedures, and

b\. Identified deficiencies (if any) were corrected, or are being
corrected, before any more shipments are made.

02.10 [Procurement and Selection of
Packagings]{.underline}.[]{#__RefHeading___Toc189653125 .anchor} For
packagings that are used by the licensee to transport or to deliver
licensed material to a carrier for transport, review the procedures and
records for the following:

a\. [Fabrication of
Packagings]{.underline}.[]{#__RefHeading___Toc189653126 .anchor} Verify,
by physical examination and examination of records, whether new
packagings have been fabricated in accordance with the approved design
(i.e., NRC COC or DOT specification). For packagings supplied by,
procured, or leased from a vendor or supplier, verify that the licensee
has obtained a written statement from such supplier, certifying that the
packaging has been fabricated in accordance with a NRC-approved quality
assurance program.

b\. [DOT Revalidation of Foreign-Approved
Packagings]{.underline}.[]{#__RefHeading___Toc189653127 .anchor} Verify
that for foreign‑approved packagings used by the licensee, such designs
have been revalidated by DOT, and the licensee possesses a copy of the
applicable foreign certificate, DOT revalidations, and documentation
referenced therein, which relate to the use and/or maintenance of the
packaging and actions to be taken before shipment (49 CFR 173.473 and
10 CFR 71.21).

02.11 [Preparation of Packages for
Shipment]{.underline}.[]{#__RefHeading___Toc189653128 .anchor}

a\. [Package Marking]{.underline}.[]{#__RefHeading___Toc189653129
.anchor} Verify that, for NRC-certificate packages or DOT-revalidation
packages of foreign origin, the outside of the package is durably and
legibly marked with the package identification marking indicated in the
COC or the DOT Competent Authority Certificate.

b\. [Advance Notification to
Consignee]{.underline}.[]{#__RefHeading___Toc189653130 .anchor} Verify
that the licensee provides, for notification to the consignee before
shipment: the dates of shipment and expected arrival, and any special
loading/unloading or operating instructions whenever any non-exempt
fissile materials and/or packages containing Ahighway route controlled
quantities@ are involved \[49 CFR 173.22(c) and 10 CFR 71.89\].

c\. [Advance Notification to
States]{.underline}.[]{#__RefHeading___Toc189653131 .anchor} Verify that
the licensee provides advance notification to the Governor of a State,
or his designee, when required, as described in 10 CFR 71.97.

NOTE: This requirement is not the same as that required for safeguards
purposes, pursuant to 10 CFR 73.72.

02.12 [Periodic Maintenance of
Packagings]{.underline}.[]{#__RefHeading___Toc189653132 .anchor} For
reusable NRC-certified, DOT specification, or DOT revalidated
foreign-made packagings, examine the licensee's procedures and records
for shipments, to verify that, before reuse, all the initial and
periodic maintenance required by the certificate, specification, or
revalidation has been performed. If possible, observe such maintenance
activities (49 CFR 173.474, 49 CFR 173.475, 10 CFR 71.85, and 10 CFR
71.87). For multi-user packages supplied by another party, the
licensee-user should obtain written certification that required periodic
maintenance and quality control measures have been conducted in
accordance with a NRC-approved quality assurance program.

02.13 [Records, Reports, and
Notifications]{.underline}.[]{#__RefHeading___Toc189653133 .anchor}
Review the licensee's records and procedures for recordkeeping and
reports to verify that a system is in place to:

a\. [Record of Shipment]{.underline}.[]{#__RefHeading___Toc189653134
.anchor} Maintain on file for three years after any shipment, a record
of each shipment of licensed material (which is not exempt there from)
and that such records contain the required information \[10 CFR
71.91(a)\].

b\. [Quality Assurance Records - Components and
Services]{.underline}.[]{#__RefHeading___Toc189653135 .anchor} Maintain,
for three years after the life of any packaging, sufficient quality
assurance records documenting evidence of the quality of packaging
components and those services that are of safety significance, including
the results of required preliminary determinations before first use of
any packaging \[10 CFR 71.85 and 10 CFR 71.91(b)\].

c\. [Quality Assurance Records - Other]{.underline}.
[]{#__RefHeading___Toc189653136 .anchor} Maintain, for three years after
the last shipment, sufficient quality assurance records that furnish
documented evidence to support the activities affecting quality
assurance of transport packages (10 CFR 71.135).

d\. [Notification of Excess Contamination or Radiation
Level]{.underline}.[]{#__RefHeading___Toc189653137 .anchor} Immediately
notify the appropriate regional office and the delivery carrier for
instances in which removable radioactive surface contamination and/or
external radiation levels on packages received in a shipment exceed the
applicable reporting limits \[10 CFR 20.1906(d)\].

e\. [Reduction in Package Effectiveness
Report]{.underline}.[]{#__RefHeading___Toc189653138 .anchor} Report to
the Director, Spent Fuel Storage and Transportation (SFST), Office of
Nuclear Material Safety and Safeguards (NMSS), within 30 days, any
instances in which there has been a significant reduction in the
effectiveness of any packaging during its use, providing additional
details of any defects of safety significance to the packaging, after
first use, and the means employed to repair such defects, to prevent
their recurrence (10 CFR 71.95).

86740-03 INSPECTION GUIDANCE[]{#__RefHeading___Toc189653139 .anchor}

03.01 [General Guidance]{.underline}.[]{#__RefHeading___Toc189653140
.anchor} In fulfilling the inspection requirements and objectives of
this procedure, the inspector should assess the adequacy of the various
aspects of the licensee's program in view of the licensee's total
program. That is, he should consider for the various transportation
activities such factors as the volume, quantity, and types of
radioactive material involved, the inherent potential radiological
hazards, the complexity of the packaging required, the number of
shipments made and received over a period of time, the number of
licensee employees involved in the activities, etc. In other words, a
Agraded approach@ should be used in assessing the adequacy of the
licensee's program, with the smaller programs requiring complete but
less complex and extensive controls than larger programs. In the same
context, the extent and scope of the inspection coverage may be adjusted
accordingly. For example, inspection of the transportation program of a
licensed processor/supplier of medical isotopes would require much
broader inspection coverage: i.e., package procurement, preparation,
delivery to carrier, radwaste shipments, etc., as contrasted with the
inspection of a radiography user, wherein the primary focus would be on
the transport of devices in private carriage. Correspondingly, the
transport program of a typical nuclear utility would focus on the
package preparation and delivery to carriers of large volumes of
radwaste materials and spent fuel shipments.

03.02 [Specific Guidance]{.underline}.[]{#__RefHeading___Toc189653141
.anchor}

[SUBSECTION A GUIDANCE FOR BASIC
REQUIREMENTS]{.underline}[]{#__RefHeading___Toc189653142 .anchor}

a\. [Inspection Requirement
02.01(c)]{.underline}.[]{#__RefHeading___Toc189653143 .anchor}
[Preparation of Packages for Shipment: Liquid Packaging
Requirements]{.underline}. These requirements are very important in
examining the packaging configurations used by suppliers of medical and
industrial isotopes. Inspectors should verify that in the Type A testing
of a given design, the licensee has considered the requirements of 49
CFR 173.412(k) relative to use of absorbent materials and/or a double
containment system. For packagings exceeding 50 cubic centimeters liquid
volume, either option is allowed, whereas for less than 50 cubic
centimeters the use of an absorbent material is required. The
configuration should be examined visually to verify that the absorbent
material is suitably positioned to contact the liquid in the event of
leakage. The package testing must also address the results of the
additional requirement of 49 CFR 173.466 for liquids, i.e., a 30-ft drop
test. For packages containing liquid greater than A~2~ and destined for
air shipments, the licensee is required to perform a leakage assessment
on each package before shipment. Leakage testing methods are described
in Regulatory Guide 7.4.

b\. [Inspection Requirement
02.01(d)]{.underline}.[]{#__RefHeading___Toc189653144 .anchor}
[Preparation of Packages for Shipment: Package Marking]{.underline}. The
specific requirements for marking of packages include:

1\. DOT proper shipping name (49 CFR 172.101 and 49 CFR 172.301).

2\. Identification number (e.g., UNXXXX or NAXXXX, 49 CFR 172.101 and 49
CFR 172.301).

3\. Gross weight, if greater than 110 pounds, AType A@ or AType B@ as
appropriate and radiation symbol for Type B, Type B(U) or Type B(M)
packages \[49 CFR172.310(a), (b), and (c)\].

4\. For DOT 7A Type A packages, the words AUSA DOT 7A Type A@ and
ARadioactive Material@ \[49 CFR 178.350\].

5\. US NRC packaging approval number \[49 CFR 173.471(b)\].

6\. For DOT specification packages within a nonspecification outer
overpack, a statement, such as, AInside Package(s) Comply with
Prescribed Specification(s)@ \[49 CFR 173.25(a)(4)\].

7\. ARADIOACTIVE -LSA,@ or ARadioactive-SCO@ in the case of LSA or SCO
(Surface contaminated objects) packages transported as exclusive-use
\[49 CFR 173.427(a)(6)(vi)\].

8\. Name and address of the consignee or consignor \[49 CFR 172.301(d)
\].

9\. AUSA,@ in conjunction with the NRC-certificate or DOT-specification
marking, if the package is destined for export \[49 CFR 172.310(e)\].

10\. An appropriate arrow symbol to indicate upward positioning, where
liquid contents are involved in a combination package \[49 CFR
172.312(a)\].

11\. ARQ@ if reportable quantity of hazardous substance \[172.324(b)\].

The physical requirements for legibility and location of package
markings are found in 49 CFR 172.304. Inspectors should not consider
marking requirements as a less important requirement, since they
constitute a very important element of the Hazardous Materials
ACommunications@ requirements, along with labels, placards, and shipping
papers. Marking deficiencies quite often indicate that the licensee is
generally unaware of other regulatory requirements and are often
accompanied by more serious packaging deficiencies.

c\. [Inspection Requirement
02.01(e)]{.underline}.[]{#__RefHeading___Toc189653145 .anchor}
[Preparation of Packages for Shipment: Radiation
Monitoring]{.underline}. Licensees who package and offer for
transportation large numbers of small medical radiopharmaceuticals often
use an Aassembly-line@ process, in which the loaded package travels past
a fixed, preset radiation detector. Inspectors should carefully examine
such systems, to ensure that they, in fact, are effective in ensuring
compliance with the regulatory limits for radiation levels. Another
question that frequently arises is the placement of a specification
package (e.g., such as a radiography projector within an outer box or
other type of enclosure during transportation). The question involves
whether the radiation levels at the surface of the outer box and at 1
meter from the outer box may be used to establish the label requirements
for the overall Apackage.@ Since DOT regulations do not address this, it
is therefore permissible to apply labels, to the outer box, that reflect
radiation levels around the outer box. The inner package, which is the
authorized package, must be labeled to reflect radiation levels from
that package, without the outer box.

Assuming that the inner package (the device) is labeled and marked as a
specification package, the outer enclosure would, however, need to be
further marked with a statement such as AInside Packages Complies with
Prescribed Specification@ (49 CFR 173.25), and labeled as required,
based on the radiation levels on the [outer enclosure]{.underline}. (See
also IE Information Notice 81-02.)

> In instances where the licensee consolidates more than one inner
> package into outer overpacks, such as bags or cartons, certain rules
> for transport index (TI) determination, label entries, and markings
> are provided in 49 CFR 173.448(g).

On an [open]{.underline}, exclusive use vehicle, a package may not
exceed the 200-mrem/ hour surface limit (i.e., a 1000-mrem/hour package
must be in a [closed]{.underline} transport vehicle \[49 CFR 173.441(b)
(1) (i) and 177.842(g)\]). Inspectors, as well as licensees, should also
be aware that the 1000-mrem/hour package limit applies at the
[surface]{.underline}. Further discussion on radiation limits and other
requirements for exclusive-use shipments is provided in IE Information
Notice 80-32 (August 29, 1980) and Rev. 1 thereto (February 12, 1982).

[Preparation of Packages for Shipment: Contamination
Monitoring]{.underline}. In 49 CFR 173.443, Table 9, the expressed
limits applicable to a Awipe@ sample are stated in terms of the actual
limit on the wipe, itself. A Afactor of 10" higher limit is allowed for
packages shipped as exclusive use. Such packages are required to be at a
Afactor of 1" (2200 disintegrations/minute/100 square centimeter
beta/gamma) at the [start]{.underline} of transportation, but may rise
to a Afactor of 10" [during]{.underline} transportation (22,000
disintegrations/minute/100 square centimeter beta/gamma). Exclusive-use
vehicles in which the Afactor of 10" higher-contamination packages are
transported must be surveyed.

NOTE: For packages shipped in closed, exclusive-use vehicles dedicated
only to radioactive materials shipments and so marked, the Afactor of
10" limits may apply at the [start]{.underline} of transport \[49 CFR
173.443(d) and 177.843(b)\]. This provision does not exist in 10 CFR
71.87(i); however, inspectors should be aware that licensees may still
apply this provision even though it is not contained in 10 CFR Part 71.

A question sometimes arises concerning the performance of contamination
surveys in those cases where a package, such as a cask, is provided with
an external heat barrier or screen to achieve compliance with the heat
limits of 49 CFR 173.442(b). The question is whether the contamination
limits, as measured by wipe tests, may be taken at the surface of the
external barrier or at the surface of the cask within the barrier
screen. It is the NMSS position that the contamination limits must be
applied at the [package]{.underline} surface (including the surfaces
between the package and any removable impact limiter) even though the
heat limit is applied at the barrier surface. Monitoring of
contamination levels at the outer barrier screen might not disclose the
existence of contamination from the package or on the package.
Monitoring of the surface contamination of the cask inside the barrier
is therefore a regulatory requirement, whereas monitoring of
[both]{.underline} the cask surface and the outer barrier, would
constitute a better health physics practice. (See IE Information
Notice 83-10, March 11, 1983.)

d\. [Inspection Requirement
02.01(f)]{.underline}.[]{#__RefHeading___Toc189653146 .anchor}
[Preparation of Packages for Shipment: Package Labeling]{.underline}. If
possible, the inspector should examine one or more samples of completed,
labeled packages to verify the adequacy of this requirement. The proper
category of ARADIOACTIVE@ label to be applied to each package is based
[principally]{.underline}, but not [solely]{.underline}, on the measured
dose rates at the package surface and at 1 meter (TI). Inspectors are
also reminded that the TI assigned to the package label may be assigned
on the basis of either nuclear safety for fissile materials
[or]{.underline} radiation, whichever number is higher. What this means
is that in inspecting and surveying a package with a recorded TI, the
radiation level reading at 1 meter from a fissile package may not be
consistent with the recorded TI on the label. This is [not]{.underline}
a violation if the TI had been assigned on the basis of the nuclear
safety value and is a larger number than it would be based on the actual
radiation level at 1 meter. \[See also 49 CFR 173.403 Transport Index
definition\].

Inspectors are also reminded that LSA or SCO packages in
other-than-exclusive use are required to be [labeled]{.underline},
whereas for exclusive use, they only are required to be
[marked]{.underline} ARADIOACTIVE-LSA@, or ARADIOACTIVE-SCO,@ as
appropriate.

NOTE: The package labeling requirements of 49 CFR Part 172 Subpart E,
for purposes of [transport]{.underline}, should not be confused with the
requirements for marking packaged radwaste as Classes A, B, or C, for
purposes of shallow land disposal, pursuant to 10 CFR Part 61. Further,
the designators Classes A, B, or C [waste]{.underline} bear no direct
basis to Types A or B packages, for [transport]{.underline} purposes.

e\. [Inspection Requirement
02.02(a)]{.underline}.[]{#__RefHeading___Toc189653147 .anchor} [Delivery
of Completed Packages to Carriers: Shipping Paper
Documentation]{.underline}. Requirements for shipping paper descriptions
constitute a very important part of the hazardous materials regulatory
Acommunica­tions@ requirements, the others being labels, marking, and
vehicle placards. Generally speaking, as is the case for marking,
observation of shipping paper deficiencies may be symptomatic of more
serious deficiencies in packaging; therefore, inspectors should be
familiar with the detailed shipping paper require­ments. Generally
speaking, a shipping paper may be any type of transportation document,
i.e., bill of lading, shipping invoice, radioactive waste shipment
record, etc. However, it must contain the following elements of
[applicable]{.underline} information \[49 CFR 172.201, 172.202, and
172.203 (d)\]:

1\. The applicable DOT proper shipping name and hazard class,
ARadioactive Material,@ 49 CFR 172.101 (unless the words ARadioactive
Material@ are already contained in the name). Letters RQ or X in column
captioned AHM@ \[49 CFR 172.203(c)(2)\].

2\. The applicable identification number (UNXXXX or NAXXXX) from 49 CFR
172.101.

3\. The name of each radionuclide. Abbreviations, as taken from 49 CFR
173.435, are authorized.

4\. A description of the physical and chemical form of the material.
(For special form sources, this description is ASPECIAL FORM.@)

5\. The activity contained in each package, measured in SI units.

6\. The category of label applied to each package (ARADIOACTIVE
WHITE‑I,@ ARADIOACTIVE YELLOW-II,@ or ARADIOACTIVE YELLOW-III@).

7\. The TI (dose rate at 1 meter) assigned to each package bearing
ARADIOACTIVE YELLOW-II@ or ARADIOACTIVE YELLOW-III@ labels.

8\. For shipments tendered to a common carrier, the appropriate signed
shipper's certification; and for shipments by aircraft, the additional
statement as to acceptability for either passenger-carrying or
cargo-only aircraft. For shipments by passenger-carrying aircraft, the
additional statement of intended use in research or medical diagnosis or
treatment must also be included \[49 CFR 172.204(a); 49 CFR
172.204(c)(3), 49 CFR 172.204(c)(4), 49 CFR 172.204(d)\].

9\. The words AHighway Route Controlled Quantity@ for any shipments
containing such quantity \[49 CFR 172.203(d)(10)\].

10\. Any other descriptive information may be included after the basic
description, provided it is not inconsistent therewith \[49 CFR
172.201(a)(4)\].

In shipments where both nonhazardous and radioactive materials are
described on the same shipping paper, the radioactive materials must
appear as the first entry, or be designated by an AX@ in columnar
fashion, or be highlighted in a contrasting or other distinguishing
fashion from the nonhazardous materials.

NOTE: 10 CFR 20, Appendix G, requires that each shipment of radioactive
waste to a land disposal facility be accompanied by a manifest that
describes the shipment contents. The waste shipment receiver (e.g., the
disposal facility operator) also requires specific additional
information. In addition to shipper identification requirements and a
certification, the manifests required by 10 CFR 20, Appendix G, must
include the following information as a minimum:

\(a\) The waste class, pursuant to 10 CFR Part 61;

\(b\) A radiological description; and

\(c\) A physical and chemical description.

11\. Emergency response information that can be used in the mitigation
of an incident involving hazardous material. The information includes
immediate precautions to be taken in case of an accident or incident (49
CFR 172.602). The information may be on a separate document, but must be
maintained in the same manner as the shipping papers.

12\. Emergency response telephone number. The number must be monitored
at all times that the hazardous material is in transportation, including
storage incidental to transportation (49 CFR 172.604).

f\. [Inspection Requirement
02.02(b)]{.underline}.[]{#__RefHeading___Toc189653148 .anchor} [Delivery
of Completed Packages to Carriers: Loading and Placarding of
Non-Exclusive-Use Shipments]{.underline}. The licensee/shipper's
responsibilities in these cases mainly relate to
[furnishing]{.underline} the required placards (based on the presence of
any ARADIOACTIVE YELLOW-III@-labeled packages) to a highway carrier or
[applying]{.underline} the placards to a rail vehicle. The basic
responsibil­ity for blocking and bracing packages within the vehicle
rests with the carrier, as well as storage distance controls based on
the TIs. The [shipper]{.underline} does, however, have a responsibility
not to offer, to a carrier, for placement in a single non-exclusive-use
vehicle, packages bearing a total TI value of more than [50]{.underline}
\[49 CFR 177.842(a)\].

g\. [Inspection Requirement
02.03]{.underline}.[]{#__RefHeading___Toc189653149 .anchor} [Receipt of
Packages]{.underline}. Regulatory Guide 7.3 provides additional guidance
on these requirements found in 10 CFR 20.1906, which
[includes]{.underline} provisions for the following:

1\. Arrangements for package receipt or expeditious pickup \[10 CFR
20.1906(a)\].

2\. Monitoring external surfaces and radiation levels for certain
packages \[10 CFR 20.1906(b), (c) and (f)\].

3\. Notification of carrier and NRC when package limits or levels are
exceeded \[10 CFR 20.1906(d)\].

> 4\. Requirements for package-opening procedures \[10 CFR 20.1906(e)\].

h\. [Inspection Requirement
02.04(a)]{.underline}.[]{#__RefHeading___Toc189653150 .anchor}
[Procurement and Selection of Packagings: DOT Specification
7A]{.underline}. DOT regulations require that [each]{.underline} shipper
of a Specification 7A package maintain, on file, a written documentation
of the tests and engineering evaluation or comparative data showing that
the packaging complies with the specification. If the shipper of a
Specification 7A package is not the original designer or user of that
package, it is necessary for that shipper to obtain the package
evaluation report data from the original supplier/user or to perform the
tests himself and document the results.

Further, if a shipper makes any changes to the packaging or its maximum
authorized contents, from the description on the original test report
furnished by another person, it will be necessary to perform and
document a supplemental evaluation, addressing such changes and
demonstrating that the package will continue to meet the appropriate
performance requirements. In any case, the Abottom line@ of the
Specification 7A documentation is that the [results]{.underline} of how
the package meets the applicable environmental and test conditions must
be addressed. In this regard, inspectors may find some shippers
furnishing and relying on test results and data extracted from several
technical reports by the former agency, Energy Research and Development
Administration (ERDA), entitled, ACertification of ERDA Contractors
Packaging with Respect to DOT Specification 7A Performance
Requirements,@ Report MLM-2228, June 12, 1975, with one Supplement,
(April 15, 1976) and MLM-2324 (October 8, 1976). A question may then
arise about the sufficiency of the test data from these reports in any
given case. Judgment will then have to be exercised in assessing whether
the licensee's specific package falls within the parameters of the tests
as reported, with respect to such aspects as maximum package weight
tested, type of closure, tested content versus actual content, and
content limitations. The licensee's documentation should include an
evaluation concluding how the package meets the Spec. 7A test
requirements based on the recorded data, or any other independent
package tests that have been performed. In any case, inspectors should
[reject]{.underline} any rationale used by the licensee that the marking
[alone]{.underline} of ADOT Spec. 7A@ on the outside of the package is
sufficient fulfillment of this requirement.

i\. [Inspection Requirement
02.04(b)]{.underline}.[]{#__RefHeading___Toc189653151 .anchor}
[Procurement and Selection of Packagings: Special Form
Requirements]{.underline}. Radioactive sealed sources classified as
Aspecial form@ material must meet the physical integrity requirements,
as defined in 49 CFR 173.469 and 49 CFR 173.476. These requirements call
for [each]{.underline} shipper of a special form source to maintain, on
file, a supporting safety analysis or documenta­tion containing the
results of the testing performed on the source, to demonstrate that it
meets the special form requirements. This does not mean that each
shipper has to actually perform the tests, only that he must obtain and
retain the documentation of these tests. As a practical matter, each
licensee should establish a file of such data for each source design in
his inventory. It may be necessary, therefore, for the licensee to
procure the required information from the source manufacturer.

In many instances, qualification of the material as special form will
have no direct bearing on the type of packaging required, relative to
content limit \-- for example, where A~1~ = A~2~ (as in the cases of
Cobalt-60, Manganese-54, and Phosphorus-32), Type A packaging for A~1~
or A~2~ quantities is required, regardless of Aform.@ In such cases,
when the material has been encapsulated as a sealed source, but is
[not]{.underline} described on the shipping paper documents as Aspecial
form,@ the documentation of special form testing is not required \[49
CFR 173.476(d)\]. If the material however, [is]{.underline} described as
special form, the backup documentation [is]{.underline} required.

[SUBSECTION B GUIDANCE FOR ADDITIONAL
REQUIREMENTS]{.underline}[]{#__RefHeading___Toc189653152 .anchor}

j\. [Inspection Requirement
02.06]{.underline}.[]{#__RefHeading___Toc189653153 .anchor} [Management
Controls]{.underline}. The inspection effort should be directed at
certifying that written procedures have been established in a manner
approved by management. The procedures should be readily available to
all those having responsibility for any phase of the licensee's
transportation activity. The inspector should confirm that the
procedures include provisions for all of the [applicable]{.underline}
transport activities addressed in the Inspection Requirements Section 2
of this procedure.

In reviewing the adequacy of the licensee's program for management
controls and associated written documentation thereof, inspectors are
reminded to concurrently review, as a cross-check, the licensee's
written, approved QA program, which incorporates the elements of 10 CFR
Part 71, Subpart H.

> In reviewing the program, it will be necessary to review the
> licensee's procedures that satisfy commitments made in the QA program
> application.

k\. [Inspection Requirement
02.08]{.underline}.[]{#__RefHeading___Toc189653154 .anchor} [QA
Program]{.underline}. Further guidance on acceptable QA programs for
transport packages is provided in NRC Regulatory Guide 7.10. A key
factor in verifying this inspection requirement is to ascertain whether
the actual QA program reasonably corresponds to that which has been
described to, and approved by, NRC. Questions frequently arise regarding
fulfillment of QA requirements in those cases where there are multiple
users, as in the case of casks leased from a supplier. The NMSS position
on this, as stated in IE Information Notice 83-10, March 11, 1983, is
restated below, as follows:

1\. Each registered licensee-user should obtain a current certificate
from the package owner attesting that the packaging was designed,
procured, fabricated, assembled, tested, and is maintained in accordance
with an NRC‑approved QA program.

2\. Each registered licensee-user should provide the owner with a copy
of all QA records on maintenance, repair, or modifications to the
package, which are conducted under the licensee-user's QA program.

3\. Each licensee-user should maintain its own QA program and related
records concerning its use/operation and maintenance of the package. The
licensee‑user is also encouraged to obtain from the package owner copies
of those quality-related documents that may be useful and relevant to
the licensee-user's own QA program. (Note: This is [not]{.underline} to
imply necessarily that the package owner would be expected to provide
each user, nor is each user expected to maintain, [all]{.underline} of
the quality-related documents associated with [all]{.underline} of the
criteria of 10 CFR Part 71, Subpart H.)

Recognizing the inherent difficulties in maintaining QA records in cases
of multi-user packages, it is important to bear in mind that the
individual licensee-user is responsible for maintaining as complete a
file as possible of the QA records pertaining to package use, and
further, to establish mecha­nisms for exchange of pertinent QA records
with the package owner. It remains the responsibility of each
licensee-user that his transportation activities meet the requirements
of 10 CFR Part 71. As stated above, however, in fulfilling this
responsibility, the licensee-user has the prerogative to accept written
certifications from package owners and suppliers that certain QA
activities, not under the licensee-user's immediate control, were
conducted in accordance with an NRC-approved QA program.

l\. [Inspection Requirement
02.10(a)-(b)]{.underline}.[]{#__RefHeading___Toc189653155 .anchor}
[Procurement and Selection of Packagings: General Guidance]{.underline}.
For Type B, fissile, and certain Type A package designs certified by
NRC, a necessary reference is NUREG-0383, ADirectory of Certificates of
Compliance for Radioactive Materials Packages,@ which is issued and
updated annually by NMSS. DOT Specification Packaging designs are
published and listed in 49 CFR Part 178. Authorizations for DOT
specifications packagings are found in 49 CFR 173.415, 49 CFR 173.416,
and 49 CFR 173.417.

Inspectors should note that some of the regulatory requirements for
packaging and transporting packages of LSA or SCO have changed.
NUREG-1608, ACategorizing and Transporting Low Specific Activity
Materials and Surface Contaminated Objects,@ provides further guidance
on this subject.

m\. [Inspection Requirement
02.11(a)]{.underline}.[]{#__RefHeading___Toc189653156 .anchor}
[Preparation of Packages for Shipment: Preliminary and Routine
Determinations and Package Marking]{.underline}. Inspection of the
required preliminary and routine determinations will have some overlap
with the inspection of the licensee's QA activities on transport
packages. In reviewing the licensee's preliminary and routine
determinations, the following additional guidance is offered.

1\. In determining whether a package has any significant damage, the
package should be considered to have significant damage if such damage
would be likely to preclude the package from meeting the applicable
requirements of 10 CFR Part 71 and/or its approved design.

2\. In reviewing the adequacy of package closures, closures that involve
attempts at sealing with gaskets having visible or obvious
imperfections, field splices that are not part of an approved design,
caulking, and rusty or dirty sealing surfaces would not be considered to
be free from defects.

3\. The loading and closing of packages in accordance with written
procedures should include a determination that the packaging is
authorized for the specific intended contents, and that any lid/closure
to the main body is properly aligned, with its bolts properly torqued to
the specified values in the prescribed pattern.

4\. A record should be established by the licensee for each reusable
packaging. Because many packagings are procured in lots and without
serial numbers, the record may exist for a large quantity of packagings
specified, as in a purchase order. Special emphasis should be placed on
records that show that components important to safety have been
inspected for conformance to NRC-approved design. Depending on the type
of package, this may include structural, thermal, shielding,
containment, closure, and criticality control systems. The records may
include visual observations and physical test results.

5\. For NRC-certified packaging, the inspector should give special
attention to any applicable terms and conditions of the certificate
relating to preliminary and routine determinations and routine
maintenance.

6\. Package-marking requirements include ATYPE A" or ATYPE B@ as
appropriate, and NRC certificate number.

n\. [Inspection Requirement
02.11(b)]{.underline}.[]{#__RefHeading___Toc189653157 .anchor} [Delivery
of Completed Packages to Carriers: Loading and Placarding of
Exclusive-Use Shipments]{.underline}. The requirements herein will
relate very frequently to shipments of low-level radwaste to licensed
burial sites, quite frequently as LSA materials. Many of the questions
that arise concerning these shipments are addressed in IE Information
Notice 80-32 (August 29, 1980) and Rev. 1 (February 12, 1982).

o\. [Inspection Requirement
02.11]{.underline}.[]{#__RefHeading___Toc189653158 .anchor} [Delivery of
Completed Packages to Carriers: Advance Notice to States]{.underline}. A
list of the names and mailing addresses of the Governor's designees who
are to receive such advance notification of transportation of nuclear
waste is published annually in the [Federal Register]{.underline}
(around June 30). The reporting quantities for the report required by
NRC pursuant to 10 CFR 71.97 are currently the same as the quantities
designated by DOT as AHighway Route Controlled Quantities.@

86740-04 RESOURCE ESTIMATE[]{#__RefHeading___Toc189653159 .anchor}

Transportation safety inspection resource requirements vary greatly
depending on facility size and shipping activity. On-site inspection
hours can range from less than 1 hour at material licensee facilities
with limited shipping activity, to more than 8 hours at reactors or
other large facilities with significant shipments.

86740-05 REFERENCES[]{#__RefHeading___Toc189653160 .anchor}

05.01 [Regulations]{.underline}.[]{#__RefHeading___Toc189653161 .anchor}

a\. 49 CFR Parts 100-178, AHazardous Materials Regulations,@ of the U.S.
Department of Transportation, revised annually, as of October 1.

b\. 10 CFR Part 71, APackaging and Transportation of Radioactive
Material.@

c\. U.S. Postal Service Publication No. 6, Dec. 1975 ARadioactive
Material,@ as amended by U.S. Postal Bulletin, June 30, 1982, pp. 2-5.

d\. International Atomic Energy Agency, ARegulations for the Safe
Transport of Radioactive Material,@ Safety Series No. 6, 1985 (As
Amended 1990, 1996), IAEA, Vienna, Austria.

05.02 [NRC Information
Notices]{.underline}.[]{#__RefHeading___Toc189653162 .anchor}

a\. 79-21, ATransportation and Commercial Burial of Radioactive Waste,@
September 5, 1979.

b\. 80-24, ALow-Level Waste Burial Criteria,@ May 30, 1980.

c\. 80-25, ATransportation of Pyrophoric Uranium,@ May 30, 1980.

d\. 80-32, AClarification of Certain Requirements for Exclusive-Use
Shipments of Radioactive Materials,@ August 29, 1980.

e\. 80-32, Rev. 1, February 12, 1982.

f\. 81-02, ATransportation of Radiography Devices,@ January 23, 1981.

g\. 81-32, ATransfer and/or Disposal of Spent Generators,@ October 23,
1981.

h\. 82-24, AWater Leaking From UF6 Overpacks,@ July 20, 1982.

i\. 82-47, ATransportation of Type A quantities of Non-Fissile
Radioactive Material,@ Nov. 30, 1982.

j\. 83-10, AClarification of Several Aspects Relating to Use of
NRC-Certified Transport Packages,@ March 11, 1983.

k\. 84-14, AHighlights of Recent Transport Regulatory Revisions by DOT
and NRC,@ March 2, 1984.

l\. 84-50, AClarification of Scope of Quality Assurance Programs for
Transport Packages Pursuant to 10 CFR 50, Appendix B,@ June 21, 1984

m\. 84-72, AClarification of Conditions for Water Shipments Subject to
Hydrogen Gas Generation,@ September 10, 1984

n\. 85-46, AClarification of Several Aspects of Removable Radioactive
Surface Contamination Limits for Transport [Packages,@
June](mailto:Packages.( June) 10, 1985

o\. 86-18, ANRC On-Scene Response during a Major [Emergency,@
March](mailto:Emergency.(March) 26, 1986

p\. 86-67, APortable Moisture/Density Gauges: Recent Incidents and
Common Violations of Requirements for Use, Transportation, and Storage,@
October 10, 1986

q\. 86-86, AClarification of Requirements for Fabrication and Export of
Certain Previously Approved Type B Packages,@ June 11, 1987

r\. 87-26, ACracks in Stiffening Rings on 48-inch Diameter UF6
Cylinders,@ June 11, 1987

s\. 87-31, ABlocking, Bracing, and Securing of Radioactive Materials
Packages in Transportation,@ July 10, 1987

t\. 87-37, ACompliance with the General License Provisions of 10 CFR
Part 31,@ August 10, 1987

u\. 87-47, ATransportation of Radiography Devices.@ October 5, 1987

v\. 87-55, APortable Moisture/Density Gauges: Recent Incidents of
Portable Gauges Being Stolen or Lost.@ October, 29, 1987

w\. 88-33, (Bulletin), "Recent problems involving the Model No. SPEC 2-T
Radiographic Exposure [Device,@ May](mailto:Device.(May) 27, 1988

x\. 88-16, AIdentifying Waste Generators in Shipments of Low-Level Waste
to Land Disposal Facilities.@ April 22, 1988

y\. 88-18, AMalfunction of Lockbox on Radiography Device.@

z\. 88-33, ARecent Problems Involving the Model SPEC- 2T Radiographic
Exposure Device,@ April 25, 1988

aa. 88-62, ARecent Findings Concerning Implementation of Quality
Assurance Programs by Suppliers of Transport Packages.@ May 27, 1988

bb. 88-66, AIndustrial Radiography Inspection and Enforcement.@ August
12, 1988

cc\. 88-101, AShipment of Contaminated Equipment between Nuclear Power
Stations.@ December 28, 1988

dd. 89-24, ANuclear Criticality Safety.@ March 06, 1989

ee. 89-74, AClarification of Transportation Requirements Applicable to
Return of Spent Radiopharmacy Dosages from Users to Suppliers.@ November
07, 1989

ff. 90-24, ATransportation of Model SPEC 2-T Radiographic Exposure
Device.@ April 10, 1990

gg. 90-27, AClarification of the Recent Revisions to the Regulatory
Requirements for Packaging of Uranium Hexafluoride (UF6) for
Transportation.@ April 30, 1990

hh. 90-35, ATransportation of Type A Quantities of Non-Fissile
Radioactive Materials.@ May 24, 1990

ii\. 90-50, AMinimization of Methane Gas in Plant Systems and Radwaste
Shipping Containers.@ August 8, 1990

jj. 90-66, AIncomplete Draining and Drying of Shipping Casks,@ October,
20, 1990

kk. 90-82, ARequirements for Use of NRC-Approved Transport Packages for
Shipment of Type A Quantities of Radioactive Material,@ December 31,
1990

ll. 91-39, ACompliance with 10 CFR Part 21, AReporting of Defects and
Noncompli­ance.@ June 17, 1991

05.03 [NRC Regulatory
Guides]{.underline}.[]{#__RefHeading___Toc189653163 .anchor}

a\. 7.1, AAdministrative Guide for Packaging and Transporting
Radioactive Material,@ June 1974. ML 003739261

b\. 7.2, APackaging and Transportation of Radioactively Contaminated
Biological Material,@ June 1974. ML003739263

c\. 7.3 AProcedures for Picking Up and Receiving Packages of Radioactive
Materials,@ May 1975. ML003739403

d\. 7.4, ALeakage Tests on Packages for Shipment of Radioactive
Materials (For Comment),@ June 1975. ML003739407

e\. 7.5, AAdministrative Guide for Obtaining Exemptions From Certain NRC
Requirements Over Radioactive Material Shipments,@ June 1975 or May
1977. ML 003739415

f\. 7.6, ADesign Criteria for the Structural Analysis of Shipping Cask
Containment Vessels,@ February 1977 or March 1978.ML003739418

g\. 7.7, AAdministrative Guide for Verifying Compliance With Packaging
Requirements for Shipments of Radioactive Materials (For Comment),@
August 1977. ML003739493

h\. 7.8, ALoad Combinations for the Structural Analysis of Shipping
Casks for Radioactive Material," May 1977, March 1989 (Revision 1).
ML003739501

i\. 7.9, AStandard Format and Content of Part 71 Applications for
Approval of Packages for Radioactive material,@ March 1979 or January
1980, 03/05. ML003739363, ML050540321, ML033630447

j\. 7.10, AEstablishing Quality Assurance Programs for Packagings Used
in the Transport of Radioactive Material,@ January 1983, June 1986
(Revision 1), March 2005 (Revision 2), March 2005. ML003739404,
ML050540330, ML040410577

k\. 7.11, AFracture Toughness Criteria of Base Material for Ferritic
Steel Shipping Cask Containment Vessels with a Maximum Wall Thickness of
4 Inches (0.1 m),@ June 1991. ML003739413

l\. 7.12, AFracture Toughness Criteria of Base Material for Ferritic
Steel Shipping Cask Containment Vessels with a Wall Thickness Greater
than 4 Inches (0.1 m) But Not Exceeding 12 Inches (0.3 m),@ June 1991.
ML003739424

05.04 [Other Publications]{.underline}.[]{#__RefHeading___Toc189653164
.anchor}

a\. U.S. Department of Transportation, A2000 Emergency Response
Guidebook.@

b\. U.S. Department of Transportation, ARadioactive Material Regulations
Review,@ RAMREG 001-98.

c\. NUREG-1608, ACategorizing and Transporting Low Specific Activity
Materials and Surface Contaminated Objects.@

d\. NUREG-1660, AU.S. Specific Schedules of Requirements for Transport
of Specified Types of Radioactive Materials Consigments.@

e\. Generic Letter 96-07, AInterim Guidance on Transportation of Steam
Generators.@

f\. "Memorandum of Understanding between the NRC and DOT," July 7, 1979.

END

ATTACHMENT 1

[Revision History for IP
86740]{.underline}[]{#__RefHeading___Toc189653165 .anchor}

+--------+--------+------------------------+-----+-------+-------------+
| Comm   | Issue  | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date   |                        | ain | ining | Resolution  |
| Tr     |        |                        | ing | Compl | Accession   |
| acking |        |                        | Nee | etion | Number      |
| Number |        |                        | ded | Date  |             |
+--------+--------+------------------------+-----+-------+-------------+
| N/A    | 10     | Researched commitments | No  | N/A   | N/A         |
|        | /30/08 | for 4 years and found  |     |       |             |
|        |        | none.                  |     |       |             |
|        | CN     |                        |     |       |             |
|        | 08-030 | IP 86740 was revised   |     |       |             |
|        |        | to capture the new 10  |     |       |             |
|        |        | CFR Part 71 and 49 CFR |     |       |             |
|        |        | regulations.           |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+