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Archived Web Page: Draft Regulatory Document RD-364Joint Canada - United States Guide for Approval of Type B(U) and Fissile Material Transportation Packages

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7.0 PACKAGE OPERATIONS

This section of the application should describe the operations, as required by 10 CFR Part 71 (71.31(c), 71.35(c), 71.43(g), 71.47(b-d), 71.87, 71.89) and Paragraph 807(d) of TS-R-1 as referenced in Paragraph 7(1)(a) of the PTNS Regulations, used to load a package and prepare it for transport, presenting the steps sequentially in the actual order in which they are performed. The operations should describe the fundamental steps needed to ensure that the package is properly prepared for transport, consistent with the package evaluation in Sections 2-6 of the application. The regulatory requirements for package operations are 10 CFR 71.87 and Paragraph 502 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations.

The package should be operated in accordance with detailed written procedures that are based on and consistent with the operations described in this section of the application. The package operations should be consistent with maintaining occupational radiation exposures as low as reasonably achievable (ALARA) as required by the Standards for Protection Against Radiation in 10 CFR 20.1101(b) or Paragraph 302 of TS-R-1.

The package operations presented in the application should not be expected to be detailed procedures that could be implemented without expansion. Rather, the package operations should be an outline that focuses upon those steps that are important to assuring that the package is operated in a manner consistent with its evaluation for approval. Compliance with the submitted package operations will be included in the certificate by reference as a condition of approval. Procedural details that are not important to safety should not be included in the application. Operational steps should normally be presented in sequential order, as applicable. Guidance on preparing both the detailed procedures and the package operations included with an application can be found in NUREG/CR-4775 Guide for Preparing Operating Procedures for Shipping Packages [24].

7.1 Package Loading

This section should describe loading-related preparations, tests, and inspections of the package, including the inspections made before loading the package to determine that the package is not damaged and that radiation and surface contamination levels are within allowable limits of the regulations.

7.1.1 Preparation for Loading

At a minimum, the operations for preparing the package for loading should ensure the following:

  1. The package is loaded and closed in accordance with written instructions;
  2. The contents are authorized by the certificate of compliance, including the use of a secondary container or containment as appropriate;
  3. The use of the package complies with the conditions of approval in the certificate of compliance, including verification that the package meets the design identified in the approval, and that the required maintenance has been performed;
  4. The package is in unimpaired physical condition;
  5. For a fissile material shipment, any special controls and precautions for transport, loading, unloading, and handling and any appropriate actions in case of an accident or delay are provided to the carrier or consignee;
  6. Any proposed special controls and precautions for handling the package are provided;
  7. Any required moderator or neutron absorber is present and in proper condition in full conformance with the approved package design; and
  8. The package is properly labelled.

In addition, the operations should describe the inspection of seals, criteria for replacement, and repair processes, if applicable, as well as the inspection of each closure device and criteria for replacement.

7.1.2 Loading of Contents

At a minimum, the operations for loading the contents should describe how the contents are loaded and how the package is closed. The loading operations should ensure the following:

  1. Any special handling equipment needed for loading and unloading is provided;
  2. Any proposed special controls and precautions for loading and handling the package are provided;
  3. Any moderator or neutron absorber, if specified, is present and in proper condition;
  4. The package has been loaded and closed appropriately in accordance with the specified bolt torques and bolt-tightening sequences;
  5. If appropriate, methods to drain and dry the package are described, the effectiveness of the proposed methods is discussed, and vacuum drying criteria are specified;
  6. For spent fuel packages, special controls and precautions regarding damaged fuel are provided; and
  7. Each closure device of the package, including any specified seals, is properly installed and secured and free of defects.

For SNF packages, if the applicant has designed the criticality control system of the packages based on the reduced reactivity of irradiated nuclear fuel assemblies due to burnup, a description of the steps involved in the measurement to independently verify the burnup of the irradiated nuclear fuel should be provided in this section. The description should include the measurement technique, type of device, the measured parameter(s), number of measurements, and the criterion for an acceptable error band on the measurement device.

7.1.3 Preparation for Transport

The operations for preparing the package for transport should address radiation and contamination surveys of the package, leakage testing of the package, measurement of the package surface temperature, package tie-down, and the application of tamper-indicating devices and appropriate marking and labelling. At a minimum, the preparation for transport operations should ensure the following:

  1. The level of non-fixed (removable) radioactive contamination on the external surfaces of each package offered for shipment is ALARA, and within the limits specified in DOT regulation 49 CFR 173.443 or Paragraph 508 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations;
  2. Radiation survey requirements of the package exterior are described to ensure that limits specified in 10 CFR 71.47 or Paragraph 531 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations and Paragraph 572 of TS-R-1 as referenced in Subsection 15(5) of the PTNS Regulations are met;
  3. The temperature survey requirements of the package exterior ensure that limits specified in 10 CFR 71.43(g) or Paragraphs 617, 652, and 662 of TS-R-1 which are incorporated in Subsection 1(1) of the PTNS Regulations by reference to Paragraph 650 of TS-R-1 are implemented;
  4. Leakage testing of the package meets the assembly verification leakage test requirements specified in ANSI N14.5 or ISO 12807;
  5. A tamper indicating device is incorporated that, while intact, indicates that the package has not been opened by unauthorized persons;
  6. Any system for containing liquid is adequately sealed and has adequate space or other specified provision for expansion of the liquid;
  7. A check is made to ensure that any pressure relief device is operable and properly set;
  8. Any structural part of the package that could be used to lift or to tie-down the package during transport is rendered inoperable for that purpose unless it satisfies the design requirements for lifting or tie-down attachments as required by 10 CFR 71.45 or Paragraph 608 of TS-R-1 which is incorporated in Subsection 1(1) of the PTNS Regulations by reference to Paragraph 650 of TS-R-1;
  9. Any proposed special controls and precautions for transport, handling and any proposed special controls in case of accident or delay are specified;
  10. Marking and labelling of the package are done in accordance with 49 CFR 172.310 and 172.403 or Paragraphs 535-540 and 542-546 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations;
  11. Written instructions to the carrier are provided for packages that require exclusive use shipment because of external radiation levels; and
  12. Before delivery of a package to a carrier for transport, the licensee has sent or made available to the consignee any special instructions needed to safely open the package.

7.2 Package Unloading

This section should include inspections, tests, and special preparations of the package for unloading. As applicable, this section should also describe the operations used to ensure safe removal of fission gases, contaminated coolant, and solid contaminants.

7.2.1 Receipt of Package from Carrier

The process for receiving the package should address radiation and contamination surveys and inspection of the tamper-indicating device. This section should also describe any proposed special controls and precautions for handling and unloading.

The U.S. regulations require the receiver to conduct a radiation and contamination survey of packages in accordance with 10 CFR 20.1906, Procedures for Receiving and Opening Packages. Subsection 21(3) of the Canadian Packaging and Transport of Nuclear Substances (PTNS) Regulations requires that the consignee verify whether the package is damaged, shows evidence of having been tampered with, has any portion of the fissile material outside the confinement system, and has any portion of the contents outside the containment system (PTNS Regulations are found at /eng/lawsregs).

The operations should be presented sequentially in the order of performance for receiving the package from the carrier. At a minimum, the receipt operations should ensure the following:

  1. The requirements of 10 CFR 20.1906 or PTNS subsection 21(3) are met;
  2. The package is examined for visible external damage;
  3. Steps to define actions to be taken when the tamper-indicating device is not intact or when surface contamination or radiation survey levels are too high, are provided;
  4. A list of any special handling equipment needed for unloading and handling the package is provided;
  5. Any proposed special controls and precautions for unloading and handling the package are provided;
  6. Procedures controlling the radiation level limits on unloading operations are provided; and
  7. Procedures for the safe removal of, if any, fission gases, contaminated coolants, and solid contaminants are provided.

7.2.2 Removal of Contents

This section should describe the appropriate operations and method for opening and removing contents from the package. The operations should be presented sequentially in the order of performance for removing the contents following package receipt. At a minimum, the operations should ensure that:

  1. The closure is removed appropriately;
  2. The contents are removed appropriately; and
  3. Verification is made that the contents are completely removed.

7.3 Preparation of Empty Package for Transport

This section should describe the inspections, tests, and special preparations needed to ensure that the packaging is verified to be empty and is properly closed, and that the radiation and contamination levels are within allowable limits. In addition, this section should address the appropriate requirements of 49 CFR 173.428, Empty Class 7 (Radioactive) Materials Packaging, or the requirements in Paragraph 520 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations.

The operations should ensure the following:

  1. The packaging is empty;
  2. Appropriate inspections and tests of the package are performed before transport, to ensure that the requirements of 10 CFR 71.87(i) or Paragraph 508 of TS-R-1 as referenced in Subsection 16(4) of the PTNS Regulations are met; and
  3. Special preparations of the packaging, to ensure that the interior of the packaging is properly decontaminated and closed in accordance with the requirements of 49 CFR 173.428 or Paragraph 520 of TS-R-1, are described.

7.4 Other Operations

This section should include the provisions for any special operational controls (e.g., route, weather, shipping time restrictions).

7.5 Appendix

The appendix should include a list of references, applicable pages from referenced documents, detailed descriptions and analysis of processes or protocols, graphic presentations, test results, and other supplemental information.

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