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# Clarification of Certain Requirements for Exclusive-Use Shipments of Radioactive Materials

## HPPOS-084 PDR-9111210232

See IE Information Notice No. 80-32 dated August 29, 1980.

This notice clarifies requirements regarding open and closed transport vehicles, personnel barriers, packages enclosed within an outer cask shield, exclusive-use shipments, and radiation limits. See Revision 1 to this IE information notice (HPPOS-085).

In mid-1979, NRC initiated an enhanced program for inspection of shipments of radiation materials. This augmented inspection / enforcement program prompted a number of questions on the proper application of certain regulatory requirements. These questions involved the problems and deficiencies associated with exclusive-use highway shipments of low-level radioactive wastes. The purpose of this Notice is to discuss the following fourteen questions to clarify the application of certain requirements, particularly the application of the limits of radiation levels of exclusive-use shipments as prescribed in 49 CFR 173.393 (j).
        - What limits would apply to packages being transported on an open, exclusive-use transport vehicle?
        - What constitutes a closed transport vehicle?
        - In the situation described above, is such a "personnel barrier" considered to be the "package" or a component of the package?
        - In the above situation, what are the limits for radiation levels on the packages within such a personnel barrier?
        - If "packages" such as drums are enclosed within an outer cask "shield" (as opposed to a personnel barrier or closed vehicle) wherein the other shield is necessary to achieve compliance with the limit of either 173.393 (i) or 173.393 (j), may the inner drum (s) be considered to be the package"?
        - In the situation described above, would the levels of radiation on the inner drums be limited to the levels of 173.393 (j) (1) (e.g., 1000 mrem/hr at 3 ft)?
        - In monitoring the radiation levels at the external surface of the transport vehicle, as prescribed in 173.393 (j) (2), do the limits apply at the bottom and top of the vehicle, as well as at the sides?
        - In the above situation, does this mean that in applying the limit of 173.393 (j) (3) (e.g., 10 mrem/hr at 6 ft from the sides of the vehicle) the limit also applies at the top and "bottom" of the vehicle?
        - In 173.393 (j) (3) the radiation level limit is prescribed at 10 mrem/hr at 2 m (6 ft) from the outer lateral surfaces of an exclusive-use vehicle. Since 2 m is 6.6 ft, which limit would apply (6 ft or 6.6 ft)?
        - What is an "exclusive-use" shipment?
        - Frequently shipments of radioactive waste are made as "exclusive-use" shipments under arrangements whereby the original generator of the waste utilizes the services of a waste collector (i.e., "broker) who in turn usually engages a common or contract carrier to transport the shipment or transport the material in his own vehicle as a private carrier. On occasion this "broker" may also be the consignee (e.g., a waste burial site operator). Because of this complex arrangement, confusion often arises as to which party is responsible for performing the regulatory requirements of the "shipper" or "consignor." Can you clarify this?
        - In the above situation, assume that a "broker" picks up or arranges for pickup radioactive waste from more than one generator's facility for transport as a single shipment by a common carrier or by himself as a private carrier. Is it not required that an exclusive-use shipment be from a "single consignor"?
        - In an exclusive-use shipment of LSA materials, the shipper is required by 173.392 (c) (9) to provide specific instructions to the carrier for maintenance of exclusive-use shipment controls. What should such specific instructions include?
        - 49 CFR 173.393 (j) (4) requires that the radiation level in any "... normally occupied position in the car or vehicle ..." be limited to 2 mrem/hr. Where should this limit be applied in a tractor with a sleeper cab?

**Regulatory references:** 10 CFR 71, 49 CFR 173

**Subject codes:** 7.1, 12.17

**Applicability:** All

Page Last Reviewed/Updated Friday, October 13, 2017