HPPOS-263 PDR-9306070226

Policy and Guidance Directive FC 84-18, “Transportation of Irradiator Units Not Meeting Current Requirements of 10 CFR Part 71”

See the memorandum from R. E. Cunningham to Regional Administrators (and Branch Chiefs of the Division of Fuel Cycle and Material Safety) dated November 6, 1984. Prior to the adoption of the requirements of 10 CFR 71 in 1966, irradiators could be transported without being evaluated under the accident damage test requirements that are now incorporated in 10 CFR 71. Many of these irradiators are in use and from time to time need to be transported to a new location.

In those cases where the irradiator cannot be practically transported in packaging which meet requirements of 10 CFR 71, the licensee may request a one-time shipment in accordance with 10 CFR 71.7 and 71.41 (c). The shipment can only be authorized by Headquarters. In applying for a one-time shipment, the licensee must provide adequate controls such that the shipment will not endanger life or property.

Information that is typical of what the licensee has been requested to submit to Division of Fuel Cycle and Material Safety, NMSS, to support one-time shipments includes:

1. The circumstances as to why an existing package cannot be used,

2. Engineering drawings of the irradiator, and

3. Information to confirm:

a. Transport during time of low road usage,

b. The use of good roads which avoid residential areas to the maximum extent possible,

c. Accompaniment of the shipment by escort knowledgeable in the use of radiation survey instrument,

d. Provision an escort with appropriate survey instrument and supplies to permit the establishment of a radiation exclusion area,

e. Written procedures to be followed by the escort in an emergency situation,

f. Use of exclusive use vehicle and shoring to limit movement of package during transport, and

g. Notification of state health officials and local fire department of time and route of shipment.

Prior to applying to the NRC for its approval, the licensee should contact the State Health Officer of each state through which the shipment will be made to confirm points of contact and to discuss the proposed controls for the shipment. In several recent cases, short distance shipment of irradiators have been successfully made with the cooperation of state officials.

All requests for shipments of irradiators containing the information should be referred to the Material Licensing Branch who will coordinate the approval authorizing the shipment with the Transportation Certification Branch. All new Irradiators are expected to meet the requirements of 10 CFR 71.

Regulatory references: 10 CFR 71.7, 10 CFR 71.45

Subject codes: 12.17

Applicability: Byproduct Material