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Re: Receipt of Type B Packages
Here are a few things to keep in mind:
49 CFR 173.403... "Package means, for Class 7 (radioactive) materials, the
packaging together with its radioactive contents AS PRESENTED FOR
TRANSPORT..." [emphasis mine]
10 CFR 20.1906
(b) Each licensee shall -
(1) Monitor the EXTERNAL SURFACES [emphasis mine] of a labeled package for
radioactive contamination ...
(2) Monitor the external surfaces of a labeled package for radiation
levels..."
...
(c) The licensee shall perform the monitoring required by paragraph (b) of
this section as soon as practical after receipt of the package, but not later
than 3 hours after the package is received at the licensee's facility..."
Interpretations:
"Received" is not defined in the regulations, but a reasonable interpretation
is that, for a cask shipment, the package is considered "received" when the
cask trailer or rail car is disconnected from its motive power, i.e.
locomotive or tractor..
Since the impact limiters are an essential part of the package "as presented
for transport," and the receipt survey is only for the external surfaces of
the package "as presented for transport," surveying under the impact limiters
is NOT part of the receipt survey.
The three hours is a hard limit, which I interpret to mean completing the
survey to the point where any contamination levels or dose rates above
established limits can be identified. The % of the package to smear or scan
is a judgment call, but it should be sufficient to identify any potential
violations. It dose not mean that the survey has to be fully documented and
reviewed.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
Bill.Teer@rw.doe.gov wrote:
> Does anyone have experience in the receipt of Type B packages - preferably
> spent fuel casks?
> I am particularly interested in the procedures for surveying and swiping
> the package within the three hour
> time limit. Is it necessary to swipe the entire surface of the package,
> or, in the case of a spent fuel cask,
> do the impact limiters have to be removed during the three hour period?
> How rigid is the NRC about the
> three hours? If the surveys are started within three hours, but not
> completed, is that acceptable?
>
> Our concern arises because of the possibility of receiving multiple casks
> (up to five) at one time on a
> dedicated train at the Yucca Mountain Repository.
>
> Any comments will be appreciated.
>
> Bill Teer
> M&O Contractor for OCRWM
>
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