NUREG/CR-4775

UCID-20820

Guide for Preparing

Operating Procedures

for Shipping Packages

Prepared by M. C. Witte

Lawrence Livermore National Laboratory

Prepared for

U.S. Nuclear Regulatory

Commission
NOTICE

This report was prepared as an account of work sponsored by an agency of the United States

Government. Neither the United States Government nor any agency thereof, or any of their

employees, makes any warranty, expressed or implied, or assumes any legal liability of responsibility for any third party's use, or the results of such use, of any information, apparatus,

product or process disclosed in this report, or represents that its use by such third party would

not infringe privately owned rights.

NOTICE

Availability of Reference Materials Cited in NRC Publications

Most documents cited in NRC publications will be available from one of the following sources:

1. The NRC Public Document Room, 1717 H Street, N.W.

Washington, DC 20555

2. The Superintendent of Documents, U.S. Government Printing Office, Post Office Box 37082,

Washington, DC 20013-7082

3. The National Technical Information Service, Springfield, VA 22161

Although the listing that follows represents the majority of docum-,its cited in.NRC publications,

it is not intended to be exhaustive.

Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC me'noranda; NRC Office of Inspection

and Enforcement bulletins, circulars, information notices, inspection and investigation notices;

Licensee Event Reports; vendor reports and correspondence; Commission papers; and applicant and

licensee documents and correspondence.

The following documents in the NUREG series are available for purchase from the GPO Sales

Program: formal NRC staff and contractor reports, NRC-sponsored conference proceedings, and

NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of

Federal Regulations, and Nuclear Regulatory Commission Issuances.

Documents available from the National Technical Information Service include NUREG series

reports and technical reports prepared by other federal agencies and reports prepared by the Atomic

Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents available from public and special technical libraries include all open literature items,

such as books, journal and periodical articles, and transactions. Federal Register notices, federal and

state legislation, and congressional reports can usually be obtained from these libraries.

Documents such as theses, dissertations, foreign reports and translations, and non-N RC conference

proceedings are available for purchase from the organization sponsoring the publication cited.

Single copies of NRC draft reports are available free, to the extent of supply, upon written

request to the Division of Information Support Services, Distribution Section, U.S. Nuclear

Regulatory Commission, Washington, DC 20555.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process

are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available

there for reference use by the public. Codes and standards are usually copyrighted and may be

purchased from the originating organization or, if they are American National Standards, from the

American National Standards Institute, 1430 Broadway, New York, NY 10018.
NUREG/CR-4775

UCID-20820

Guide for Preparing

Operating Procedures

for Shipping Packages

Manuscript Completed: September 1988

Date Published: December 1988

Prepared by

M. C. Witte

Lawrence Livermore National Laboratory

7000 East Avenue

Livermore, CA 94550

Prepared for

Division of Engineering

Office of Nuclear Regulatory Research

U.S. Nuclear Regulatory Commission

Washington, DC 20555

NRC FIN A0374

This report imposes no requirements.
PREFACE

This report provides guidance for writing manuals of operating procedures for shipping

packages used for radioactive materials. The work was performed by the Lawrence Livermore

National Laboratory (LLNL) and was funded by the Division of Engineering within the Office of

Nuclear Regulatory Research of the Nuclear Regulatory Commission (NRC).

The author wishes to thank Charles J. Temus of Nuclear Packaging, Federal Way,

Washington, and Larry Fischer of LLNL for their significant contributions to this report; and

William Campbell, Herman Graves and Charles Williams of the NRC, for their comments and

support.

ii
TABLE OF CONTENTS

Section Title Page

INTRODUCTION ....................................................................................... v

B ack ground ................................................................................... v

Purpose and Scope .......................................................................... v

Procedures Format and Content ............................................................ v

1.0 OPERATING PROCEDURES IN SAFETY ANALYSIS REPORTS ..................... 1

1.1 Summary of Operating Requirements and Restrictions ................................ 1

1.2 General Information ........................................................................ 1

1.3 Package Loading ............................................................................ 1

1.4 Shipment Preparation ....................................................................... 1

1.5 Package Receipt ............................................................................. 3

1.6 Package Unloading ......................................................................... 3

1.7 Inspection and Maintenance ............................................................... 3

1.8 Records and Reporting Requirements .................................................... 3

1.8.1 Records for Each Shipment ...................................................... 3

1.8.2 Records of Package History ...................................................... 3

1.8.3 R eports .............................................................................. 4

2.0 DETAILED OPERATING PROCEDURES MANUALS .................................... 5

2.1 Summary of Operating Requirements and Restrictions ................................ 5

.2.2 General Information ........................................................................ 5

2.2.1 Planning .......................................................................... 5

2.2.2 Personnel Qualifications ........................................................ 5

2.2.3 Equipment ........................................................................ 6

2.2.4 Quality Assurance ............................................................... 6

2.3 Package Loading ............................................................................ 6

2.3.1 Package Preparation ............................................................. 6

2.3.2 Contents Insertion ............................................................... 7

2.3.3 Closure Placement, Package Assembly

and Leak Testing ................................................................. 8

iii
2.3.4 Closing and Sealing ............................................................. 8

2.3.5 Package Transfer or Handling ................................................. 9

2.3.6 Decontaminating ........................................ 9

2.4 Shipment Preparation .................................................................... 10

2.4.1 Requirements Prior to Shipment .............................................. 10

2.4.2 Testing ........................................................................... 11

2.4.3 S urveying ........................................................................ 11

2.4.4 Marking and Labeling .............................................. ......... 12

2.4.5 Securing to Vehicle .............................................................. 12

2.4.6 Preparation of Empty Package for Transport ............................... 13

2.4.7 Shipping Documents and Notifications ..................................... 13

2.5 Package Receipt ........................................................................... 14

2.5.1 G eneral ........................................................................... 14

2.5.2 Inspections and Surveys ........................................................ 14

2.5.3 Removal from Vehicle .......................................................... 15

2.5.4 Cleaning and Flushing ........................................................ 16

2.6 Package Unloading ......................................................................... 17

2.6.1 Transfer Preparations ........................................................... 17

2.6.2 Closure Removal ................................................................ 17

2.6.3 Contents Removal .............................................................. 18

2.7 Inspection and Maintenance ............................................................... 18

2.8 Records and Reporting Requirements ................................................... 19

2.8.1 Records for Each Shipment ................................................... 19

2.8.2 Records of Package History ................................................... 19

2.8.3 R eports ........................................................................... 19

DEFINITIONS .......................................................................................... 20

RELATED DOCUMENTS ............................................................................. 23

iv
INTRODUCTION

Background

To protect the health and safety of the public, shipping packages used to transport radioactive

materials must be operated in accordance with subpart G of Title 10 of the Code of Federal

Regulations (CFR) Part 71 and according to the quality assurance plan approved by the Nuclear

Regulatory Commission (NRC). Specific criteria for using a shipping package must be

documented in a Safety Analysis Report (SAR) that is reviewed and approved by the NRC prior to

the first use of the shipping package. A Certificate of Compliance (CofC) is issued by the NRC,

which authorizes the use of a package for transporting radioactive material. The shipper then

develops detailed operating procedures based on criteria in the approved SAR and CofC. If there

are conflicts between the CofC and the operating procedures, the CofC governs.

There is a wide variation in the operating procedures currently used for shipping radioactive

material to and from various nuclear facilities. This NUREG/CR gives guidelines which are based

on the broad experience that exists in the shipping industry and are consistent with subpart G of 10

CFR 71.

Purpose and Scope

Two separate documents related to package operations are prepared for shipping packages.

The first is a section of the SAR, usually Section 7.0, which provides information on package

operations that is specific to the package. This document is referred to in this NUREG/CR as "operating procedures in the SAR." The second document is a detailed manual that is used by the

package operators and handlers. It comprises all information included in the operating procedures in the SAR (in greater detail), plus all additional information necessary for package operations

which is not package specific. This second document is referred to in this NUREG/CR as the "operating procedures manual."

This NUREG/CR addresses both the operating procedures in the SAR and the operating

procedures manual for packages used to transport radioactive material. The purpose of this

NUREG/CR is to give guidance in writing the operating procedures for the SAR and the operating procedures manual. General and specific requirements that should be included in each document

are provided.

This NUREG/CR has two main sections. The first section covers information which should

appear in the operating procedures section of the SAR. The second section covers information

which should appear in the more detailed operating procedures manuals used by the operators and

handlers of shipping packages.

The individual sections of this NUREG/CR recommend the format, contents, and levels of

detail for both documents.

Procedures Format and Content

The same basic format is used for both the operating procedures portion of the SAR and the

operating procedures manual. The major headings of the procedures for both documents are listed

below:

1. Summary of Operating Requirements and Restrictions

2. General Information

3. Package Loading

4. Shipment Preparation

v
5. Package Receipt

6. Package Unloading

7. Inspection and Maintenance

8. Records and Reporting Requirements

vi
1.0 OPERATING PROCEDURES IN SAFETY ANALYSIS REPORTS

This section addresses the contents of the operating procedures provided in the SAR. These

SAR operating procedures, usually in section 7.0, contain all package-specific information about

package operation drawn from all other sections of the SAR. These procedures in the SAR

become the foundation for the more detailed of operating procedures manual.

1.1 Summary of Operating Requirements and Restrictions

. This section is intended to alert the reader to all requirements and restrictions related to

package operations. Details should not be included here, but rather in sections 1.2 through 1.8.

Each section of the SAR (i.e., thermal, structures, containment, criticality, shielding, etc.) should

provide input to this section, as shown in Figure 1-1. All requirements and restrictions related to

package operations should be briefly listed in this summary. This list will include drawing and

revision numbers for all package components (as required for operations); a description of the form

(solid, liquid, powder, etc.) and fissile load of the contents; any package handling restrictions

(such as lifting height limits or dual load path requirements); any neutron poison, moderator, and

gap requirements; expected gamma and neutron radiation levels, and locations of any streaming

paths; and any closure (such as closure lid bolt torques necessary for containment) and component

testing (such as pressure taps) requirements.

1.2 General Information

The operating procedures in the SAR should list any special equipment required for handling

the particular package and include all pertinent details.

The operating procedures in the SAR should include appropriate quantitative and qualitative

criteria for determining that important activities have been satisfactorily accomplished.

1.3 Package Loading

The operating procedures in the SAR provide instructions on package loading. Instructions

on the following items might be included:

1. Listing any special equipment that may be needed.

2. Ensuring that package sealing surfaces have been properly prepared and protected.

3. Checking that all payload treatment processes performed subsequent to package

loading are appropriate for the particular payload in question, and that process

equipment operators are familiar with both processing procedures and the package

operating procedures. 4. Checking that all package components operate as designed and have been tested if

necessary.

5. Contents insertion.

6. Closure placement and package assembly.

7. Decontamination of exterior surfaces of shipping package and transport vehicle.

8. Package transfer from the loading site to the transport vehicle.

1.4 Shipment Preparation

The operating procedures in the SAR must provide instructions on shipment preparation.

These instructions should include at least the following items:

-1-
Structural

" Lifting configuration

" Tie-down configuration

" Handling limits

General Information

" Drawings

" Decay heat

" Source terms

" Form of contents

Thermal

* Temperatures

* Pressures

* Degradation

Operating Procedures

OPERATING

RESTRICTIONS

" Decay heat

" Environment

" Pressure

" Source terms

" Structural

INSTRUCTIONS

" Package loading

" Shipment preparation

" Package receipt

" Package unloading

" Documentation

required

PROVIDE

ASSURANCE OF:

" Contents

" Configuration

" Compliance

" ALARA

Criticality

" Neutron poison

" Gap dimensions

" Fissile contents

Shielding

" Gamma radiation levels

" Neutron radiation levels

" Streaming paths

Containment

" Release limits

" Closure requirements

" Component check

Figure 1-1 The operating procedures in the SAR include information from all other

sections of the SAR.

-2-
1. Required package testing prior to release for transport.

2. Securing package to vehicle, including acceptable tie-down configurations.

3. Rendering unused lifting devices inoperable.

4. Temperature survey requirements.

5. Radiation survey requirement, including a determination of surface contamination. •6. Decontamination inspection and any other requirements for preparation of empty

package for transport.

1.5 Package Receipt

The operating procedures in the SAR should give instructions to the package recipient on at

least the following items:

1. Ensuring that radiological surveys and safety inspections of both the packaging and

the transport vehicle are made.

2. Verifying that the contents are properly identified and in what form they are

1.6 Package Unloading

The operating procedures in the SAR provide instructions for package unloading.

Instructions on the following items should be included:

1. Any special equipment that may be needed.

2. Closure removal.

3. Contents removal.

4. Inspection of interior of packaging after contents have been removed.

5. Possible preparation of packaging for short- or long-term empty storage.

1.7 Inspection and Maintenance

This section of the operating procedures in the SAR refers to Chapter 8 of the SAR, titled

"Acceptance Tests and Maintenance Program."

1.8 Records and Reporting Requirements

1.8.1 Records for Each Shipment

Title 10 CFR 71.91 requires the licensee to maintain for a period of two years after shipment

a record of each shipment of licensed material, and gives a list of information that is to be recorded.

Title 10 CFR 20.401(b) gives additional record keeping requirements including survey and

monitoring requirements. Title 10 CFR 21.51 also requires the maintenance of records.

1.8.2 Records of Package History

The licensee shall make all records available to the NRC for inspection, upon reasonable

notice. The licensee shall maintain, during the life of the packaging to which they pertain,

sufficient quality assurance records to furnish documentary evidence of the quality of packaging

components that have safety significance and of services affecting quality. The records to be

maintained include results of the determinations required by 10 CFR 71.85, and results of

monitoring, inspection, and auditing of work performance during the design, fabrication,

assembly, testing, modification, maintenance, and repair of the packaging. In addition, records

required by 10 CFR 20.402(c)(2) must be maintained until the NRC authorizes their disposition.

-3-
The operating procedures in the SAR should specify how and where these records are to be

maintained.

1.8.3 Reports

Incident reporting requirements are given in 10 CFR 71.95, 10 CFR 20.402, 10 CFR

20.403, 10 CFR 20.405, 49 CFR 171.15, 49 CFR 171.16, 49 CFR 171.17, and 49 CFR 174

through 177. These regulations specify conditions and timing for reporting incidents including the

following: any significant reduction in package effectiveness during use, any defects with safety

significance found after the first use of a package, any loss or theft of licensed material, exposure

to personnel or to the public above levels specified in 10 CFR 20.403(b), contamination or

suspected contamination, and any fire, spillage or breakage. The operating procedures in the SAR

should specify all package-specific reporting requirements required by these regulations.

-4-
2.0 DETAILED OPERATING PROCEDURES MANUALS

This section addresses the detailed operating procedures manual which is written for the package

handlers and operators. This manual is based, in large part, on the operating procedures section of

the SAR.

2.1 Summary of Operating Requirements and Restrictions

This section is intended to alert the reader to all requirements and restrictions related to

package operations. All such requirements and restrictions delineated in the SAR should be listed.

This list will include drawing and revision numbers for all package components (as required for

operations); a description of the form (solid, liquid, powder, etc.) and fissile load of the contents;

any handling restrictions (such as lifting height limits or dual load path requirements); any neutron

poison, moderator, and gap requirements, expected gamma and neutron radiation level, and

locations of any streaming paths; and any closure (such as closure lid bolt torques necessary for

containment) and component testing (such as pressure taps) requirements. Details should not be

included here, but rather in the appropriate section 2.2 to 2.8. The list of applicable drawings

needs to appear only once in the procedures manual so that it is a simple revision to update the

drawings if this is required during the lifetime of the package.

2.2 General Information

2.2.1 Planning

Operating procedures should stress the importance of planning each operation carefully,

before any action is taken. Planning should include a review of the operating procedures and

related drawings to assure that packaging, shipping, receiving, storage, and handling activities can

be accomplished as specified. Planning should also include listing any anticipated problems and

possible solutions.

2.2.2 Personnel Qualifications

Persons who perform any duties in shipping package operations should be trained in

handling and inspecting the specific package, as well as in general techniques in safe handling of

radioactive materials. The operating procedures should describe the required training for a

particular shipping package system.

The training should include, but not be limited to:

a. Field training and trials

b. High-consequence operations training and briefing for possible exposure to chemical or

radiological hazards

c. ALARA training

d. Written tests

e. Review of appropriate sections of the SAR, CofC, regulations, and other applicable

documents, including the NRC approved QA program for transport packages.

The training should be of sufficient depth to thoroughly familiarize the personnel with the

specific types of radioactive materials and with the specific packaging that they will be handling.

After the initial in-depth training, persons involved in shipping package operations should undergo

an annual refresher course. Those persons who perform inspection, examination, or testing of

shipping packages should go through training such as that required by ANSI/ASME NQA-1.

-5-
2.2.3 Equipment

All equipment required for each aspect of shipping package operations should be listed at the

front of each section where the equipment is discussed in the operating procedures. This list

should include all necessary specifications. If the same equipment is used for several different

operations (e.g., package loading and package unloading), it should, nevertheless, be included in

every section where the use of the equipment is discussed, with a reference for the specifications to

the first section where the equipment is listed.

The operating procedures should list measures to assure that tools, gages, instruments, and

other measuring and testing devices used in activities affecting quality are properly controlled,

calibrated, and adjusted at specific times to maintain accuracy within necessary limits, per the

requirements of 10 CFR 71.125.

2.2.4 Quality Assurance

As used in this guide, quality assurance (QA) comprises all those planned and systematic

actions necessary to provide confidence that the shipping package operating procedures will

provide the necessary guidance so that all package operations will be performed.

The operating procedures should include appropriate quantitative and qualitative acceptance

criteria for determining that important activities have been satisfactorily accomplished, per the

requirements of 10 CFR 71.111.

In addition, the operating procedures should instruct the registered user of a package to

obtain and maintain on file the certification from the supplier of the packaging that those elements

of QA doie by that supplier were in fact accomplished in accordance with the supplier's QA

program.

2.3 Package Loading

2.3.1 Package Preparation

Operating procedures for loading radioactive material packaging should require the following checks before the payload is placed within the package:

1. That all appropriate documents have been reviewed by operating personnel (the SAR, the

CofC, the applicable portions of 10 CFR 71 and 49 CFR 173, and all other documents

referenced by the procedures) and are available for review if necessary.

2. That the CofC permits the radioactive material to be shipped within the particular package

used. This determination must be made in accordance with the guidelines provided in 10

CFR 71.83, when applicable.

3. That the package has been properly maintained, i.e., that all required periodic maintenance

has been performed and documented within the scheduled requirements of the CofC, SAR,

and maintenance program. This check may include verification on the QA received from the

package supplier.

4. That package sealing surfaces have been properly prepared and protected so that the package

will seal reliably.

5. That all required rigging and hoists are available and rated adequately for their intended use.

-6-
6. That all payload treatment processes performed subsequent to package loading (e.g.,

dewatering, solidification, volume reduction, and cooling) are appropriate for the particular

payload in question, and that process equipment operators are familiar with both the

processing procedures apd the package operating procedures. The processing personnel

should determine that the particular process employed is not inconsistent with the package

handling requirements, as specified in the operating procedures.

7. That packaging interior contamination levels are not excessive so that significant

contamination could be imparted to the payload itself.

8. That any check valves operate as designed.

9. That any other non-passive systems, such as cooling or closure systems, operate properly

and without undue force.

10. That all closure fasteners and devices are of the proper material and grade, and that they

operate properly.

11. That all required parts of the packaging, processing equipment, and shoring (if required) are

available and ready for use.

12. That all seals which will not be disturbed during the loading or package closure process have

been properly leak-tested since their last disturbance, if such a test is required by the package

CofC or SAR. In this way, exposure to leak test personnel may be minimized.

It may be desirable to cover some or all of the exterior of the package prior to loading as a

means of minimizing any possible decontamination efforts that may be required. Also, some seals

may require special protective devices to be installed before contents are placed within the package.

Operating procedures should describe such appropriate protective measures.

2.3.2 Contents Insertion

Procedures for contents insertion will vary greatly depending on the particular use of the

packaging. In some cases, as in a multi-use package used to transport various types of low-level

waste from a power plant to a disposal site, the operating procedures for the packaging should

reference payload-specific procedures for the insertion process, and should delineate all pertinent

operational limits or cautions that should be addressed by those procedures. For example, when

contents are inserted through a package secondary closure device and are subjected to a contents

dewatering process, the operating procedures should indicate any temperature, handling, or

material requirements the package design may impose on the dewatering process. Package

operating procedures should require that processing personnel review these requirements and

demonstrate by written documentation that the requirements are met.

Loading requirements to ensure criticality safety should be explicitly stated. Other chemical

and physical hazards of the payload should also be stated as well as what measures should be taken

to avoid exposing personnel to hazardous situations. For example, the chemical and physical

(phase change) properties of uranium hexafluoride are very unstable in many situations. These

properties should be discussed in conjunction with proper handling procedures of the material and

packaging so that the operator will appreciate the considerations involved in the event of

inadvertent deviations.

Operating procedures should describe inspections or cleaning procedures required after the

contents are inserted. These procedures may include a visual check to ensure that debris has not

accumulated on seal surfaces during the loading operation, that liquid fill lines that may be required

-7-
by the package design or use are flushed, or that all loading hardware has been removed from the

package.

If the package is not to be closed and shipped immediately, the operating procedures should

describe interim measures which should be taken immediately following loading to keep exposure

to personnel ALARA and to protect essential packaging features such as valves and seals.

2.3.3 Closure Placement, Package Assembly, and Leak Testing

If any interim closure measures are to be employed following package loading, operating

procedures should give direction on readying the package for final closure. Procedures should be

written to minimize exposure to operations personnel while the package is being so prepared.

To ensure proper closure, operating procedures should describe all inspections necessary

immediately prior to closure placement. Seals should be given a final check to ensure that they are

free from debris and have not been damaged during loading operations. Operating procedures

should specify any shoring requirements that are effective.

Operating procedures should specify any special handling requirements for placement or

operation of the closure device. These might include care to reduce the possibility of seal damage,

to improve fastener fit-up, or to reduce operator exposure.

If the package must be vented to allow proper placement of closure devices (as with a bore

seal), the procedure should be described. The procedure should anticipate possible closure

problems and give suggested methods of overcoming them. This may include the acceptability of

employing various kinds of force to complete the installation of any of the various closure devices

used in the package design.

Operating procedures should direct the order of installation of all closure devices and

fasteners as well as any torque requirements placed on closure fasteners. If leak testing is

required, operating procedures should specify when testing should be performed and the

acceptance criteria. Operating procedures should, at a minimum, reference an acceptable leak test

procedure but may include elements of the leak test within the operating procedure itself.

Operating procedures should direct the proper order of assembling of various package parts

such as overpacks. If a special shipping structure such as a skid or pallet is to be used with the

packaging, the interface and assembly of the package with this hardware should be described in

detail.

2.3.4 Closing and Sealing

The closing and sealing of a package is important in determining the performance of the

package in both normal and accident events. The extra care taken in a well written procedure, as

well as during performance of the procedure, will result in reduced maintenance, less repeated

work, and a reduction in personnel exposure.

These step-by-step procedures should have sufficient precautions for cleanliness, gasket

condition, proper preload on lid fasteners, venting, purging (if required), and any other necessary

requirements for the specific package. In addition to the required precautions, the procedure

should give some troubleshooting guidance if the closure cannot be properly secured initially.

The procedure should have sufficient detail to ensure that the final configuration is as shown

on the SAR drawings. The closure procedures should not prescribe a final package configuration

in conflict with the requirements of any of the applicable analyses in the SAR.

-8-
Some types of payloads, such as low level waste, have the potential for the generation of

explosive gases. Operating procedures for packages that could transport these payloads should

allow for venting and/or purging to eliminate this potential hazard. Many CofC for such packages

require verification of gas generation conditions or require venting prior to release for shipment.

For these cases, appropriate precautions must be implemented in the procedure to assure that these

requirements are met.

2.3.5 Package Transfer or Handling

Operating procedures for transfer of the packaging from the loading site to the transport vehicle should reflect considerations similar to those expressed in Section 2.3.1. These

considerations include radiological, rigging, and compliance with the design considerations in the

SAR. A check should be made to ensure that the transport vehicle is appropriate for the

transportation of the load.

Specific consideration should be given to the radiological situation. Even if all handling is to

be performed within a radiologically controlled boundary, caution should prevent any spread of

contamination. For the package, the main concern is external contamination. Potential for external

contamination is particularly high when partially assembled packages are handled, or during the

testing of the package prior to shipping.

As with all procedures, those governing handling of the package should be a detailed stepby-step procedure. If the package can be handled in a partially assembled state, the procedure

should relate clearly what is required for each step. Information such as how secure the lids have

to be, or whether they have to be installed at all should be clearly stated to prevent mishandling or

damage to the package. Many large-diameter packages require that their lids are completely

installed prior to lifting to prevent damage. Design-specific precautions coupled with good rigging

and radiological practices will provide a reasonable procedure for the handling of most packages.

2.3.6 Decontaminating

The exterior surfaces of a shipping package and the transport vehicle should be essentially

free of removable radioactive contamination. The contamination levels should be ALARA and

shall not exceed regulatory limits.

Both 10 CFR 71.87(i) and 49 CFR 173.443 require that limits for removable external

radioactive contamination be met when measured on a wipe taken on a shipping package surface.

The limits also apply to any transport vehicle used to transport radioactive material. Measuring

techniques other than wiping may be used in accordance with the referenced regulations.

These guidelines should be considered in developing decontamination operation procedures:

1. Prior to being placed into the unloading area where contamination can occur, the shipping

package should be placed onto a soft transportable surface such as wood or plastic. This

action reduces the amount of contaminants that might become imbedded into the surface that

supports the weight of the shipping package. A sheet of plastic or paper which is disposed

of upon each use may further reduce contamination.

2. A protective surface coating or bag may be installed to reduce or eliminate contamination

from specific areas of the shipping package. The protective surface coating or bag should be

removable after operations have been completed.

-9-
3. If the shipping package is to be submerged into contaminated water and a protective coating

or bag is not used, the outer surface should be wetted with water prior to immersion. This

has the effect of sealing the pores in the metallic and painted surfaces.

4. After the shipping package has been placed into the loading/unloading area and the closure

has been removed, a protective shield may be installed in the closure region to prevent

contaminants from falling onto exterior surfaces of the package while the radioactive contents

are being removed or inserted.

5. If the shipping package is immersed into contaminated pool water, the entire exterior surface

should be rinsed immediately after the package is raised from the pool water. The exterior

surfaces should be dried with composite padding or cloth rags, which should not contain any

chemicals, oils, etc. If a sleeve is to be used prior to immersion in the pool, the operating

procedure should give explicit instructions as to its use.

6. A decontamination agent should be applied, rinsed off, and then dried with clean padding or

rags over sections of the package. The decontaminating agent should not contain oils, sulfur,

or halogens or other chemicals that could damage the shipping package surface, mask

smearable contaminants, or inadvertently add unwanted elements into the pool water.

7. Fibrous nonmetallic abrasive scrubbing pads which will not scratch the package surface may

be used to scrub contaminated areas, especially the area on which the shipping package sat

during operations.

8. After each segment of the shipping package has been decontaminated, a radiation monitor

should survey the package surface. Decontaminating and surveying of the package should be

repeated until the limits in 2.1 are not exceeded.

2.4 Shipment Preparation.

2.4.1 Requirements Prior to Shipment

Prior to each shipment of licensed material, the shipper must ensure that the requirements of

49 CFR 173.475 and 10 CFR 71.87 have been satisfied. Examples of these requirements are:

1. The packaging is proper for the contents to be shipped;

2. The packaging is in unimpaired physical condition, except for superficial marks;

3. Each closure device of the packaging, including any required gasket, is properly installed,

secured, and free of defects;

4. For fissile material, each moderator and neutron absorber, if required, is present and in

proper condition.

5. Each special instruction for filling, closing, and preparation of the packaging for shipment

has been followed;

6. Each closure, valve, or other opening of the containment system through which the

radioactive content might escape is properly closed and sealed;

7. Each packaging containing liquid in excess of an A2 quantity and intended for air shipment

has been tested to show that it will not leak under an ambient atmospheric pressure of not

more than 0.25 atmosphere, absolute, (0.25 kilograms per square centimeter or 3.6 psia).

The test must be conducted on the entire containment system, or on any receptacle or vessel

within the containment system, to determine compliance with this requirement;

8. The internal pressure of the containment system will not exceed the design pressure during

transportation;

-10-
9. External radiation and contamination levels are within the allowable limits specified in this

subchapter;

10. Any system for containing liquid is adequately sealed and has adequate space or other

specific provision for expansion of the liquid;

11. Any pressure relief device is operable and set in accordance with written procedures;

12. The package has been loaded and closed in accordance with written procedures; and

13. Any structural part of the package which could be used to lift or tie down the package during

transport is rendered inoperable for that purpose unless it satisfies the design requirements of

10 CFR 71.45.

In addition, the shipper must ensure that the requirements of 10 CFR 71.85, giving

determinations required prior to first use, have been satisfied and documented. Also, the shipper

must ensure that the records required by 10 CFR 71.91 are complete. The shipper must also

determine that the packaging has been maintained in accordance with the maintenance schedule and

maintenance program as presented in the SAR and CofC. The shipper should ensure that if

applicable, the requirements of 10 CFR Part 73 have been taken into account. The operating

procedures should explicitly list all requirements of this section.

2.4.2 Testing

Prior to release of a package for shipment, several tests may be required. Although these

tests need to be performed before the final radiological surveys, some radiation and contamination

surveys should be performed before the start of any testing, for the benefit of the testing personnel.

The specific testing required for any package depends on the design and the payload the

package is carrying. The required testing that should be referenced or described in the operating procedure can be found in the applicable regulatory guide, such as NRC Regulatory Guide 7.4 for

leak testing, and in the CofC and SAR for the specific package. The basis for these requirements

can be found in the SAR.

The shipper must ensure that the accessible package surface temperatures will not exceed the

limits specified in 10 CFR 71.47 at any time during transportation.

The test procedures should be detailed, specifying all special tools, as well as possible

corrective actions to be taken if the package does not pass any particular test. The procedure

should emphasize safety and radiological control for the operator (ALARA). Supplemental

information that may aid in resolving potential problems may be added to the procedure by

appendices or references. Examples of helpful supplemental information might be a listing of

potential problems and the appropriate corrective action, or detailed cleaning procedures.

2.4.3 Surveying

Prior to releasing the package for shipment, the package and surrounding area must undergo

a complete radiation and radiological contamination survey. The surveys at the time of shipment

are required by 49 CFR 173.441, 49 CFR 173.443, 10 CFR 71.47, and 10 CFR 71.87(i). The

results of these surveys must, at a minimum, meet the levels set by the NRC and the Department of

Transportation (DOT). Some sites and facilities have more restrictive limits that must be met prior

to release of the package. The procedures should reference the government regulatory limits as

well as levels that may be specific to the site.

The procedure requires detailed radiological surveys to ensure that the external surfaces of the

package have no smearable contamination beyond the limits specified. The procedure should give

guidance regarding strategic survey techniques considering the specific geometry of the package.

A check list of survey areas, including known areas of potential contamination such as

-11-
penetrations, closure areas, and other contamination trap areas, should be provided to ensure

proper surveying.

"Wrapping" the exterior of transport packages in order to achieve compliance with removable

contamination limits is not an acceptable practice, unless the wrapping itself had been addressed in

the package SAR.

A visual survey of the complete package should ensure that it is assembled correctly. This

survey should cover the general condition of the package including verification that tamperindicating devices are installed correctly; lifting eyes are covered, if required; fasteners are secured

correctly; and personnel barriers, impact limiters, sunshields, and/or rain covers are correctly

installed and secured. The operating procedure should include a check list for this survey.

2.4.4 Marking and Labeling

The marking and labeling of the package depends on the type of package and the payload.

Some of the labeling is permanent and other labeling is shipment-specific.

The permanent labeling basically consists of that information required by 10 CFR 71.85.

This includes model number, gross weight, and a package identification number assigned by the

NRC. These items are usually included in the name plate information, and the model and

identification number is conspicuously and durably marked on the side of the package. All

permanent labeling is usually installed during fabrication of the package and does not need to be

discussed in the operating procedure. The general condition of this permanent labeling should be

checked prior to each shipment.

The detailed labeling of the packaging is shipment-specific. The basis for this labeling is the

payload description which should be carefully reviewed prior to any labeling. The separate

procedure should require the package and vehicle to be labeled per 49 CFR 173.444 and 49 CFR

173.471. Any old labels from previous shipments should be removed.

The procedure should also cover the proper placarding of the vehicle and labeling of the

package. Per 49 CFR 173.446 and 49 CFR 173.427 the procedure should give a clear definition

of what is considered to be an empty package and how it should be labeled. Determining and

labeling a package as empty will influence a number of handling actions, such as the required

testing. Placards should be secured to prevent loss or change during transport.

2.4.5 Securing to Vehicle

The system by which the package is secured to the transport vehicle must meet all applicable

DOT requirements. The operating procedures should indicate proper tie-down configuration(s),

which are in agreement with the tiedown analysis presented in the SAR. Loads used in the SAR to

size the tiedown structure, which is a structural part of the packaging itself, are not necessarily the

same as those used to design the parts of the tiedown system, which are not structurally part of the

package. Elements of the tie-down system not structurally part of the package are covered by

applicable DOT (49 CFR 177.842(d) and 49 CFR 393.100, 102, and 104) and industry standards,

such as ANSI N14.2 and N14.25, and not by 10 CFR 71. The configuration of the tie-downs,

however, is germaine to the SAR analysis and, therefore, must be carefully respected, e.g., load

paths which are assumed present in the SAR actually are present, and load paths which are not

specifically noted in the SAR are not present. Operating procedures describing acceptable tie-down

configurations should use nomenclature consistent with that used in the SAR.

Due to the high mass density of many package designs, operating procedures should require

that transport vehicle load ratings be reviewed for adequacy in light of the concentrated load.

-12-
Loads from the entire tie-down system should be combined with weight effects to ensure that the

vehicle structure is adequate. Vehicle flexibility coupled with road-induced vibration can cause

tiedown systems to work loose or fail. Therefore, the tie-down load path should be as direct as

possible without compromising any required configuration constraints. Operating procedures for

especially heavy packages, particularly those licensed for exclusive use shipments, should require

that the main structure and tie-down system of the transport vehicle be inspected for integrity prior

to release of the package for shipment. The operating procedure should contain a check list for this

inspection. It should include, at a minimum, a visual inspection of main beam web-to-flange

welds for cracks, beam webs for cracks, and tie-down structure for any signs of distortion or

failure. The tie-down structure includes the entire load path from the package back into the main

structural elements of the vehicle. Wooden decking materials, if present, should be inspected for

integrity.

The operating procedures should also reference any other restrictions to the tie-down system described in the SAR or the package CofC. These restrictions may include interface materials,

blocking restrictions, allowable bearing surfaces,, feasibility of placing cargo above the package, stacking, temperature restrictions, center of gravity locations, package orientations, or power, pneumatic, or hydraulic requirements.

The operating procedures should require that all devices on the package which could be used

for lifting, but are not capable of resisting three times the weight of the package without yielding,

are provided with a suitable disabling device or cover prior to release of the package for shipment. Likewise, all features on the package which could be used as tie-down devices, but are not

designed to be used as such, should be similarly disabled. The operating procedures should

specifically note which devices require such treatment and which do not.

2.4.6 Preparation of Empty Package for Transport

After the contents have been removed safely, a reusable package should be inspected per the

requirements of 49 CFR 173.427 to determine its suitability for shipment as an empty radioactive

material package. If the package is to be reloaded prior to being released from the licensed facility, then this inspection should not be required. If it is determined that the package interior does not

meet the requirements of 49 CFR 173 for empty radioactive material packaging, then operating procedures should require that the package either is decontaminated per the requirements of Section

2.3.6 or is prepared for shipment as a Type A or B package, as applicable per the requirements of

the package CofC and 49 CFR 173.

2.4.7 Shipping Documents and Notifications

The operating procedures should cover the various types of payloads that could be shipped

and the required documentation and notifications. The paperwork and classification of the

shipment should be completed in accordance with the DOT and NRC requirements. These

requirements include 10 CFR 71.91 for Records, 10 CFR 71.95 for Reports, 10 CFR 71.97 for

Advanced Notification, and 49 CFR 173.471 for the use of U. S. NRC approved packages. This section in the operating procedure should not give a detailed description of the paperwork and

classification process. However, it should reference standards such as ANSI N14.10 and NRC

Regulatory Guides such as 7.1, 7.2, and 7.3 which give guidance in filling out the appropriate

documentation.

The CofC and the SAR should be checked to ensure that the proposed shipment is allowed

for the specific package. The description of the payload in the shipping documents should be in a

form that can be readily correlated to that description in the package CofC.

-13-
In addition to the documentation and notification required by the federal regulations specified

above, the separate radioactive material shipping procedure used at a specific site should cover any

local or state notification or documentation requirements.

In addition to the documentation required for transport, other documentation may be required

for the specific contents. This may include a Radioactive Shipping Report (RSR) or certification to

the requirements of 10 CFR 61 for low level waste shipments.

2.5 Package Receipt

2.5.1 General

The section on package receipt in the operating manual should cover two general areas: 1)

regulatory requirements and 2) technical inspections that must be made to establish the condition of

the package and payload.

The written procedures should, at a minimum, reference the surveys and inspections that are

required by law immediately upon receipt of the package and prior to opening or handling. The

NRC and the DOT regulations are primarily concerned with the assurance that the receiver is

properly licensed, that the written procedures have been provided for the use of the package, and

that the surveys and inspections performed on the package indicate that it was properly used. The

majority of these functions are covered under 10 CFR 20.205. All procedures should reference

this regulation controlling the receipt of radioactive material packages.

Title 10 CFR 20.205 controls both the radioactive contamination surveys and the radiation

surveys that must be made on any package received. It also gives instructions on how soon after

receipt of the package that these surveys and inspections must occur. If the results of either the

contamination survey or the radiation survey exceed the limits specified, 10 CFR 20.205 requires

that the licensee report these results to the appropriate NRC Regional Office and the final delivering

carrier. The shipper should also be notified. If this is the case, the operating procedures should

direct the carrier and the package recipient to impound the package until the proper authorities have

been notified. All three, 10 CFR 20.205, 10 CFR 71.89, and 10 CFR 71.111, require that the

licensee using the package must maintain procedures for safely opening packages in which licensed

material is received.

The technical aspects of receiving a package vary from package to package and are highly

dependent on the nature of the package and the payload. However, some items are the same for all

packages. These include: insuring that appropriate paperwork is available for handling operations;

verifying what the contents are and in what form they are shipped; and insuring that radiological

surveys and safety inspections are made of both the package and the transport vehicle. Before

instructions for performing the surveys and inspections are given, careful thought should be given

to what needs to be accomplished and to any special features of the package in question. This

would relate to checking areas that could be overlooked, or checking traps for rain water, etc. In

the procedure, the person performing the first general inspection should be directed to note the

general condition of the package and the transport vehicle and to look for things that are not

specifically called out in the procedure. Many times this general inspection will detect important

details that might otherwise be overlooked. It also gives an opportunity to look at the whole

situation, allowing a number of small defects that are not significant in themselves to be evaluated

for their possible overall impact.

2.5.2 Inspections and Surveys

The most important surveys to be performed on the package are contamination and radiation

surveys. These surveys should be performed and reported in accordance with 10 CFR 20.205.

-14-
The surveys, in addition to covering radiological precautions, are a prime indicator of proper

performance and assembly of the package. Since many packages are designed with several parts,

these surveys should continue throughout the disassembly. The operating procedure should

provide a check list of survey locations and sequence. When various auxiliary features of the

packages are disassembled (e.g., sun shields, impact limiters, and personnel barriers), surveys

should be performed. These surveys will help detect any possible leakage or shifting of payload

that would impact the unloading operation.

Contamination surveys of both the package and the transport vehicle should be made to

ensure that no radioactive material (payload or package contaminant) has leaked out of the package.

The package and vehicle should also be examined for any moisture or water that may have been

trapped on the package and then moved, during normal transportation, to a visible location. This is

particularly true for pagkages that are designed to be used in and around fuel pools. Additionally,

all water should be checked for contamination and noted. Even if all water turns out to be rain

water, corrective action can be initiated to eliminate its collection or reduce its confusion with

possibly contaminated water. Large quantities of rain water, snow, etc., should be removed from

the package and transport vehicle so that they will not interfere with cleaning or opening operations

of the package.

In addition to the required radiological surveys, a comprehensive visual survey of the

package should be made to ensure that the package was properly assembled and has not sustained

any significant damage. Careful attention should be given to possible damage to components that

would affect the unloading of the package, such as lifting eyes, closure devices, or auxiliary

equipment (e.g., personnel barriers or sunshields). Specific instruction should be given -for any

special features of the package that could be easily damaged&br could- sustain damage that might not

be noted otherwise.

Labeling and placarding of a package and vehicle should be checked to ensure that they

comply with regulations and that the payload and package expected is indeed what was received.

Improper labeling and placarding should be reported to the shipper.:

The inspection should determine that any tamper, indicating devices are intact. If these

devices are~not intact, it should be reported to the licensee and shifper. Tiedowns for the package

should also be inspected for proper attachment and wear. Significant damage such as excessive

wear or broken, frayed or cracked connectors should be noted and reported to the shipper.

2.5.3 Removal from Vehicle (if required)

Normally the removal of any package from a transport vehicle requires some type of lifting or

rigging of the package. As in any lifting or rigging operation, a carefully planned procedure using

correct equipment is the best way to ensure a safe operation that does not damage the package or

other equipment. Care should be taken to plan the process, select correctly sized equipment, avoid

interface problems, etc. This care should be reflected in the written procedures.

All of the lifting and handling limitations addressed in the SAR must be met when removing

the package from the transport vehicle. This is usually covered by using good rigging practices

normally imposed at a given site. However, since 10 CFR 71 imposes special lifting requirements

that are analyzed in the SAR, assumptions in the SAR should be addressed in the procedure.

These include all aspects of the actual lift. Typically certain lift configurations are analyzed in the

SAR, and these must be used when lifting the package. This also requires that specific lift points

may or may not be used. Weights and locations of the centers of gravity of the package and

contents may be calculated and must be considered in the lifting operation. Minimum lengths of

connecting cables may be specified in the SAR to ensure that proper lift angles are met. Sometimes

-15-
spreader bars are required. The information required, whether length of sling, lift angle or

mandated special equipment, should be referenced as a minimum in the operation procedures.

The correct size of lifting equipment must be available to ensure that the proper factors of

safety are met. Using undersized lifting equipment should be avoided. The high density of the

shielding for many packages can cause deception in the true weight of the package, particularly for

smaller packages. The operating procedures should specify the correct configuration of the

package during the lift. Many waste packages are not designed to be lifted with the lids removed.

Others require overpacks, sunshields, etc., to be removed prior to lifting. Still other packages are

required to be in a certain orientation, e.g., vertical, horizontal, or horizontal in a saddle or skid.

The procedures should be specific as to whether tiedown points can be used for lifting or not. The

procedure should have precautions against using either slings as basket hitches or other equipment

in ways that may cause damage to fire shields, cooling fans, impact limiters, or other components

of the package.

As in all aspects of using and maintaining equipment, the compatibility of materials used in

and around the package must be considered. The improper use of carbon steel slings can cause

carbon steel to be embedded into the stainless steel outer shells of some packages causing

corrosion and decontamination problems.

Other considerations involve proper disconnection of the package from the vehicle. All the

connections must be disengaged completely. This includes any auxiliary equipment such as

sunshields that may interface with the removal of the package. Conversely, none of the closure

connections that actually retain the lids should be inadvertently disconnected. Caution is especially

important on bottom loading packages. When the package is lifted, additional surveys and swipes

should be taken to ensure that there is no contamination that may have been trapped under the

package.

The procedure should call attention to the placement of the package. The final location of the

package should be planned prior to the removal. Again, the high density of many package shields

may cause deception, and many floors and surfaces cannot support the weight safely. Depending

on the type and use of the package being unloaded, the type of surface that it is placed on may need

to be specified. Some packages require flat horizontal surfaces to allow for removal of the lids or

closures.

2.5.4 Cleaning and Flushing

The package should be cleaned of road dirt, snow, etc., prior to opening, when practical.

This will reduce the amount of material that would have to be treated as contaminated material. In

particular, the area around seal areas should be cleaned to reduce the chance of any spread of

contamination. The external cleanliness of many packages is especially important because of their

use in controlled clean areas such as hot cells or fuel pools.

If the package is to be placed in a pool, the package must be cleaned and flushed completely

to prevent cross contamination. If the package has any removable features such as impact limiters,

raincovers, tiedown clamps, or secondary lids, they should be removed and surveyed prior to

cleaning and flushing to ensure that nothing is trapped that can be carried into the pool. The

removal of the auxiliary equipment prior to the cleaning procedure minimizes the amount of

potentially contaminated materials.

Selection of the cleaning methodology, solution, and equipment calls for material

compatibility with the package. Many packages use outer shells of austenitic stainless steel for

ease of maintenance and decontamination, dictating the use of cleaning solutions low in chlorine.

If mechanical methods are used, their effect on the surface finish, whether bare metal or painted,

-16-
should be considered. The flush and cleaning water or solution should be checked for possible

contamination.

2.6 Package Unloading

2.6.1 Transfer Preparations

Writing the procedures for transfer preparation calls for careful attention to all of the options

that the package may have and to the various payloads that it may be carrying. More than one

procedure may be required, depending on the various options available. Depending on the

possible configurations of the package and payload, the package may need special cleaning,

flushing, and purging, or special tools and handling equipment. Checking the name plate for the

model number and checking the shipping papers for the payload description will help to ensure that

the correct procedures and equipment are used.

In the first part of the transfer procedure should be a list of any special equipment that may be

needed. This list should include any special lifting equipment and any special tools (e.g., purge

assemblies or handling fixtures) that might be required during unloading. Special lifting and

handling equipment should have both the design load value and the load test value clearly listed in

the procedure. This listing will minimize confusion when the package is used at many different

facilities, each with its own unique safety requirements.

The procedure should contain precautions to protect areas of the package that may be

sensitive to damage, such as penetrations, vents, and seal areas. It may be practical to use covers

or protectors to minimize damage. Whether these are required or optional, they should be included

in the special equipment list.

Wherever the package is placed to be opened, space limitations should be considered. There

should be sufficient space to place each disassembled part, with adequate precautions taken in the

event some of the parts are contaminated. There should also be enough overhead space for rigging

and enough lifting room to lift the payloAd out of the package, or, in the case of a bottom loading

package, to lift the package from over the payload. The operating procedures should specify any

space requirements.

2.6.2 Closure Removal

Operating procedures for closure removal should be sufficiently detailed to prevent damage to

equipment and to maximize the safety of operating personnel. Operating procedures should require

that all equipment necessary to open and unload the package is available prior to beginning closure

removal activities in order to reduce hazardous radiological or chemical exposure. The equipment

may include cranes, wrenches, shielding fixtures, rigging for all steps of unloading, transfer bells,

plumbing, or interface hardware.

Operating procedures should define which fasteners should be removed and in what order

they should be removed. A check list of all required fastener operations should be available to

ensure that these operations are completed prior to any actual movement of closures. Special

instructions should be provided where special handling considerations exist. These may include

procedural methods of minimizing stress on sensitive parts, minimizing the potential for seal

damage, minimizing decontamination problems, and alleviating ALARA concerns, e.g., clearing

the area of unnecessary personnel.

Provision should be made for the possibility of internal pressure or vacuum being present

within containment. Some cases will require pressure equalization prior to or during closure

removal operations. Operating procedures should clearly indicate the proper method for equalizing

-17-
pressure, and what precautions should be taken regarding the escape of radioactive gases. If

venting is not possible and a differential pressure could be present, specific instructions should be

provided for equalization of the pressures of the package. These may require special blow-out

prevention structures or perhaps careful heating or cooling of the package to eliminate the pressure

differential. Operating procedures should include some indication of the effect of removing closure

devices on the radiation levels near the package.

Because the internal surfaces of closures may be severely contaminated, they should be

surveyed as soon after removal as possible. It may be necessary to provide shielded storage areas

for the closures. Operating instructions should provide instructions regarding safe storage of the

closure. Other considerations regarding closure structure storage include exposure to the elements,

facility ALARA concerns, and seal protection and preservation. The operating instructions should

include special handling instructions for retention of closure fasteners to prevent loss or confusion

of fasteners. These instructions are particularly important for packages with multiple closures

employing various specialized fasteners. The operating procedures should clearly indicate the

fastener specifications for each closure.

Some packages and payload combinations may require a detailed purging operation before

opening. This procedure should be specific and give well defined acceptance criteria for

determining when the procedure is complete.

2.6.3 Contents Removal

Procedures for the removal of package contents may vary considerably depending on the type

of contents and the type of package. Some packages will require very detailed instructions for

removal of contents. Other packages, typically those designed for a wide variety of payloads,

must have removal instructions written allowing for more operator latitude. Payload-specific

instructions may be required for unusual payloads.

Packages used to transport fissile materials should have detailed instructions because of

criticality concerns. Chemical reactivity of contents may also warrant carefully detailed handling

instructions. For uranium hexafluoride, both chemical and nuclear reactivity must be avoided by procedural methods.

Specialized packaging, such as shielded sampling systems, may require contents removal

procedures written specifically around design requirements completely outside of transport

regulations or safety concerns.

Operating procedures should require that the interior of the empty packaging be inspected for

damage or the presence of loose debris, after contents are removed. Such debris should be

removed and disposed of properly, with regard for its possible level of contamination.

Operating procedures should specify proper procedures to ready the package for long-term

storage and for all long-term storage requirements, such as optimum temperature for storage,

protection from weather, seal preservation, or any other special treatment required to avoid

deterioration of the packaging.

2.7 Inspection and Maintenance

Seals and gaskets are to be inspected before and after each shipment and replaced whenever

damage is detected. Damage may include nicks, gouges, scratches, chemical damage, and damage

due to overcompression. As part of this inspection program, they are leak tested periodically and

prior to each shipment for some types of packages. Any failure of or damage to a gasket that

would affect its functionality warrants its replacement. The replacement of the seals should be in

-18-
accordance with the manufacturer's procedures. The seals are only as good as the seal surfaces.

Extreme care must be taken to ensure that the seal surfaces are undamaged. A good maintenance,

care, and inspection program will not only allow the seals to perform as required, but will preclude

expensive repair programs for the seal areas.

2.8 Records and Reporting Requirements

2.8.1 Records for Each Shipment

Title 10 CFR 71.91 requires the licensee to maintain for a period of two years after shipment

a record of each shipment of licensed material, and gives a list of information which is to be

recorded. Title 10 CFR 20.401(b) gives additional record keeping requirements including survey

and monitoring requirements. Title 10 CFR 21.51 also requires the maintenance of records.

2.8.2 Records of Package History

The licensee should make all records available to the NRC for inspection, upon reasonable

notice. The licensee maintains, during the life of the packaging to which they pertain, sufficient

quality assurance records to furnish documentary evidence of the quality of packaging components

that have safety significance, and of services affecting quality. The records to be maintained

include results of the determinations required by 10 CFR 71.85, and results of monitoring,

inspection, and auditing of work performance during the design, fabrication, assembly, testing,

modification, maintenance, and repair of the packaging. In addition, records required by 10 CFR

20.402(c)(2) must be maintained until the NRC authorizes their disposal. The operating

procedures should specify how and where these records are to be maintained. The registered user

should obtain and maintain on file certification from the package supplier that these elements of QA

done by the supplier were in fact accomplished in accordance with the NRC approved QA

programs.

2.8.3 Reports

The licensee should follow all notification requirements of 10 CFR 73.27, as well as 10 CFR

73.71, 73.72, 73.73, 73.74, and 10 CFR 21.

Incident reporting requirements are given in 10 CFR 71.95, 10 CFR 20.402, 10 CFR

20.403, 10 CFR 20.405, 49 CFR 171.15, 49 CFR 171.16, 49 CFR 171.17, and 49 CFR 174

through 177. These regulations specify conditions and timing for reporting incidents including the

following: any significant reduction in package effectiveness during use, any defects with safety

significance found after the first use of a package, any loss or theft of licensed material, exposure

to personnel or to the public above levels specified in 10 CFR 20.403(b), contamination or

suspected contamination, and any fire, spillage or breakage.

-19-
DEFINITIONS

ALARA (as low as reasonably achievable). As low as is reasonably achievable taking into account

the state of technology and the economics of improvements in relation to: (1) benefits to the public

health and safety, (2) benefits to the radiation workers who are occupationally exposed, (3) other

societal and socioeconomic considerations, and (4) the utilization of atomic energy in the public

interest.

Carrier. Person(s) or organization accepting property for transport and engaged in carriage of

property in a common, contract, or private capacity.

Cask. A type of packaging, usually large, which is heavily shielded against gamma radiation.

Certificate of Compliance (CofC). A document issued by the Nuclear Regulatory Commission

(NRC) that certifies that a radioactive material shipping package meets the requirements of 10 CFR

Part 71.

Consignee. Person or organization designated to receive a shipment following transport.

Consignor. See Shipper.

Containment System. The components of the packaging intended to contain the radioactive

material during transport.

CFR. The Code of Federal Regulations.

Exclusive Use (also referred to in some regulations as "sole use" or "full load"). The sole use of a

conveyance by a single consignor and for which all initial, intermediate, and final loading and

unloading are carried out in accordance with the direction of the consignor or consignee.

Licensee (also NRC Licensee). A person who is authorized to conduct activities under a license

issued by the NRC.

Neutron Poisons. Materials other than fissile material which will absorb neutrons, such as boron,

cadmium, or gadolinium.

Normal Form Radioactive Material. Radioactive material which has not been demonstrated to

qualify as "special form radioactive material."

Owner. See Supplier. Could also be NRC licensee

Package means the packaging together with its radioactive contents as presented for transport.

(1) Fissile material package means a fissile material packaging together with its fissile

contents.

(2) Type B package. A Type B package together with its radioactive contents. On

approval, Type B package design is designated by NRC as B(U) unless the package

has a maximum normal operating pressure of more than 700 kilopascal (100 lb/in )

gauge or a pressure relief device which would allow the release of radioactive material

to the environment under the tests specified in 10 CFR 71.73 (hypothetical accident

conditions), in which case it will receive a designation B(M). B(U) refers to the need

for unilateral approval of international shipments; B(M) refers to the need for

-20-
RELATED DOCUMENTS

In addition to this NUREG/CR, the following documents should be used in preparing operating

procedures:

1. Office of the Federal Register, Title 10, Code of Federal Regulations, Part 71,

"Packaging and Transportation of Radioactive Material," Office of the Federal Register,

Washington, D.C.

2. Office of the Federal Register, Title 10, Code of Federal Regulations, Part 20,

"Standards for Protection Against Radiation," Office of the Federal Register,

Washington, D.C.

3. Office of the Federal Register, Title 49, Code of Federal Regulations, Part 173,

"Shippers - General Requirements for Shipments and Packagings," Office of the

Federal Register, Washington, D.C.

4. American National Standard, "Guide for Writing Operating Manuals for Radioactive

Materials Packaging," ANSI N14.29, American National Standards Institute, 1430

Broadway, New York, New York 10018.

5. American National Standard, "Administrative Guide for Packaging and Transporting

Radioactive Materials," ANSI N14.10.1, American National Standards Institute, 1430

Broadway, New York, New York 10018.

6. American National Standard, "Packaging, Shipping, Receiving, Storage and Handling

of Items for Nuclear Power Plants," ANSI/ASME NQA-2, Part 2.2, American Society

of Mechanical Engineers, 345 East 47th Street, New York, New York, 10017.

7. American National Standard, "Supplementary Requirements for the Qualification of

Inspection and Testing Personnel," ANSI/ASME NQA-1, Supplement 2S-1, American

Society of Mechanical Engineers, 345 East 47th Street, New York, New York, 10017.

8. American National Standard, "Leakage Tests on Packages for Shipment of Radioactive

Materials," ANSI N14.5, American National Standards Institute, 1430 Broadway,

New York, New York 10018.

9. U.S. Nuclear Regulatory Commission, Regulatory Guide 7.4, "Leakage Tests on

Packages for Shipment of Radioactive Materials," U.S. Nuclear Regulatory

Commission, Washington, D.C.

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multilateral approval. There is no distinction made in how packages with these

designations may be used in domestic transportation. To determine their distinction for

international transportation, see DOT regulations in 49 CFR 173. A Type B package

approved prior to September 6, 1983, was designated only as Type B. Limitations on

its use are specified in 10 CFR 71.13.

Package Recipient. See Receiver.

Packaging. The assembly of components necessary to ensure compliance with the packaging

requirements of 10 CFR 71. Packaging may consist of one or more receptacles, absorbent

materials, spacing structures, thermal insulation, radiation shielding, and devices for cooling or

absorbing mechanical shocks. The vehicle, tie-down system, and auxiliary equipment may be

designated as part of the packaging.

Radioactive Material. Any material, or combination of materials, that spontaneously emits ionizing

radiation and has a specific activity in excess of 0.002 microcurie per gram of material.

Receiver. The receiver is the organization to which the radioactive material shipment is being

made. The shipper and receiver could be the same organization.

Registered User. An NRC licensee who has registered with the NRC to use a specific packaging

and in accordance with the provisions of 10 CFR 71.12.

SAR (Safety Analysis Report). A document or group of documents that provides a comprehensive

technical evaluation and review of the design, testing, operational procedures, maintenance

procedures, and quality assurance program for a packaging. The purpose of the SAR is to

demonstrate compliance with the NRC regulatory requirements.

Shipment. A quantity of freight offered by one shipper at one time to one carrier for delivery to

one consignee. A consignment is a shipment.

Shipper. The shipper is the party that has the responsibility under Federal regulations for the

radioactive materials being transported. The shipper is the NRC licensee that tias been granted

authority to possess, utilize, and transfer the radioactive material. The shipper bears the additional

responsibility for integrating the transport activities, although portions of this responsibility may be

delegated to others. The shipper certifies to the carrier that the radioactive material being shipped is

correctly identified; properly packaged, marked, labeled, and documented; and in proper condition

for transportation in accordance with applicable regulations of the Department of Transportation.

The shipper plays the principle role in the transfer of materials. The shipper may also be called the

consignor.

Shipping Package. Identical to packaging.

Special FormRadioactive Material. Radioactive material that satisfies the following conditions:

(1) It is either a single solid piece or is contained in -.sealed capsule that can be opened

only by destroying the capsule; (2) The piece or capsule has at least one dimension not less than 5 millimeters (0.197 inch);

and

(3) It satisfies the test requirements of 10 CFR 71.75.

A special form encapsulation designed in accordance with the requirements of 10 CFR

71.4(o) in effect on June 30, 1983, and constructed prior to July 1, 1985, may continue to be

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used. A special form encapsulation either designed or constructed after June 30, 1985, must meet

requirements of 10 CFR 71 applicable at the time of its design or construction.

Supplier. The supplier is an organization that provides equipment and services for the shipment of

radioactive materials. Also, packaging supplier or cask supplier.

Transferee. The transferee is the organization responsible for transferring radioactive material from

one party to another. The shipper is usually the transferee.

Type A Ouantity. A quantity of radioactive material, the aggregate radioactivity of which does not

exceed A1 for special form radioactive material or A2 for normal form radioactive material. A1 and

A2 are given in or may be determined by procedures described in Appendix A of 10 CFR 71.

Type B Quantity. A quantity of radioactive material greater than a Type A quantity.

U.S. Department of Transportation (DOT). The DOT, acting through the Materials Transportation

Bureau (MTB), promulgates rules and regulations pertaining to the packaging and transportation of

radioactive materials. For Type B packages, the certification process is under NRC jurisdiction.

The DOT focuses on carriage issues.

U.S. Nuclear Regulatory Commission (NRC). This federal agency has a broad statutory authority

over transportation of radioactive material similar to that of the DOT. Under a memorandum of

understanding between the two agencies, however, NRC limits its activities to performing safety

evaluations of packages and issuing certificates of compliance for Type B packages and packages

for fissile material. The NRC also prescribes rules for monitoring of packages on receipt, for

limiting the exposure of individuals to ionizing radiation, and for in-transit security of certain

materials. NRC imposes DOT shipping requirements by reference and inspects against them, and

enforces those requirements.

User. A user is a NRC licensee who has registered with the NRC to use a specific packaging. See

also Registered User.

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NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1, REPORT NUMBER (Assigned bv TIDC. add Vol No., ifany)

(2-84)

NRCM 1102,

3201.3202 BIBLIOGRAPHIC DATA SHEET NUREG/CR-4775

SEE INSTRUCTIONS ON THE REVERSE. UCIOD-20820

2. TITLE AND SUBTITLE 3. LEAVE BLANK

Guide for Preparing Operating Procedures for

Shipping Packages 4. DATE REPORT COMPLETED

MONTH I YEAR

5. AUTHOR(S) September 1988 6. DATE REPORT ISSUEG

M. C. Witte MONTH I YEAR

December 1988

7. PERFORMING ORGANIZATION NAME AND MAILING ADDRESS (Include ZLj Code) S. PROJECT/TASK/WORK UNIT NUMBER

Lawrence Livermore National Laboratory 9. FIN OR GRANT NUMBER

7000 East Avenue Fin No. A0374

Livermore, CA 94550

10. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code) 1 la. TYPE OF REPORT

Division of Engineering Technical

Office of Nuclear Regulatory Research TECh ncl

U.S. Nuclear Regulatory Commission b. PERIOD COVEREG (Inc/usive dares)

Washington, D.C. 20555

12. SUPPLEMENTARY NOTES

13. ABSTRACT (

2

0

0 

words ortess)

This report provides guidance for writing manuals of operating procedures

for shipping packages used for radioactive materials. Guidelines are provided

which are based on the broad experience that exists in the shipping industry

and are consistent with Subpart G of 10 CFR 71.

14. DOCUMENT ANALYSIS - a. KEYWORDS/DESCRIPTORS 15. AVAILABILITY

STATEMENT

(Radioactive Material, Shipping Containers, Operating Procedures)

Unlimited

16. SECURITY CLASSIFICATION

(This page)

b. IDENTIFIERS/OPEN.ENDED TERMS Unclassified

(This report)

Unclassified

17. NUMBER OF PAGES

18. PRICE