{"operation":"document","citation":"PHMSA Guidance, Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Object","title":"Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Object","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-06-01","effective_on":"1998-06-01","summary":"Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Object Document ML15336A927.pdf (4.03 MB) A guidebook on the proper classification and packaging of low specific activity materials and surface contaminated objects. Issued Date: Monday, June 1, 1998","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-categorizing-and-transporting-low-specific-activity-materials-932e730b.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-categorizing-and-transporting-low-specific-activity-materials-932e730b.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-categorizing-and-transporting-low-specific-activity-materials-932e730b","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/categorizing-and-transporting-low-specific-activity-materials","body":"Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Object\n\nDocument\n\n ML15336A927.pdf (4.03 MB)\n\n        A guidebook on the proper classification and packaging of low specific activity materials and surface contaminated objects.\n\n          Issued Date: Monday, June 1, 1998\n\n<<<PAGE 1>>>\n\nNUREG-1608\nRAMREG-003\nCategorizing and Transporting\nLow Specific Activity Materials\nand Surface Contaminated\nObjects\nPrepared by\nJ. Cook, R. Lewis, E. Easton, NRC\nR. Boyle, DOT\nR. Pope, ORNL\nU.S. Nuclear Regulatory Commission\nOffice of Nuclear Material Safety and Safeguards\nU.S. Department of Transportation\nResearch and Special Programs Administration\n\n<<<PAGE 2>>>\n\nAVAILABILl1Y NOTICE\nAvailability of Reference Materials Cited in NRC Publications\nMost documents cited in NRC publications will be available from one of the following sources:\n1. The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC\n20555-0001\n2. The Superintendent of Documents, U.S. Government Printing Office, P. O. Box 37082,\nWashington, DC 20402-9328\n3. The National Technical Information Service, Springfield, VA 22161-0002\nAlthough the listing that follows represents the majority of documents cited in NRC publica-\ntions, it is not intended to be exhaustive.\nReferenced documents available for inspection and copying for a fee from the NRC Public\nDocument Room Include NRC correspondence and internai NRC memoranda; NRC bulletins,\ncirculars, information notices, inspection and investigation notices: licensee event reports;\nvendor reports and correspondence; Commission papers; and applicant and licensee docuw\nments and correspondence.\nThe following documents in the NUREG series are available for purchase from the Government\nPrinting Office: formal NRC staff and contractor reports, NRG-sponsored conference pro·\nceedings, international agreement reports, grantee reports, and NRC booklets and bro-\nchures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-\ntions, and Nuclear Regulatory Commission Issuances.\nDocuments available from the National Technical Information Service include NUREG-series\nreports and technical reports prepared by other Federal agencies and reports prepared by the\nAtomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.\nDocuments available from public and special technical libraries include all open literature\nitems, such as books, journal articles, and transactions. Federal Register notices, Federal\nand State legislation, and congressional reports can usually be obtained from these libraries.\nDocuments such as theses, dissertations, foreign reports and translations, and non-NRC con-\nference proceedings are available for purchase from the organization sponsoring the publica-\ntion cited.\nSingle copies of NRC draft reports. are available free, to the extent of supply, upon written\nrequest to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear\nRegulatory Commission, Washington DC 20555-0001.\nCopies of industry codes and standards used in a substantive manner in the NRC regulatory\nprocess are maintained at the NRC Library, Two White Flint North, 11545 Rockville Pike, Rock-\nville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted\nand may be purchased from the originating organization or, if they are American National\nStandards, from the American National Standards Institute, 1430 Broadway, New York, NY\n10018-3308.\n\n<<<PAGE 3>>>\n\nNUREG-1608\nRAMREG-003\nCategorizing and Transporting\nLow Specific Activity Materials\nand Surface Contaminated\nObjects\nManuscript Completed: June 1998\nDate Published: July 1998\nPrepared by\nJ. Cook, R Lewis, E. Easton, U.S. Nuclear Regulatory Commission\nR. Doyle, U.S. Department of Transportation\nR. Pope, Oak Ridge National Laboratory\nSpent Fuel Project Office\nOffice of Nuclear Material Safety and Safeguards\nU.S. Nuclear Regulatory Commission\nWashington, DC 20555-0001\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 Seventh Street, SW\nWashington, DC 20590-0003\n\n<<<PAGE 4>>>\n\n\n\n<<<PAGE 5>>>\n\nABSTRACT\nThe primary purpose of this guidance is to assist shippers in preparing low specific activity\nmaterials (LSA) and surface contaminated objects (SCOs) for shipment in compliance with\nFederal regulations. Guidance is provided in question and answer format on the classification,\ncategorization, packaging and transportation of LSA and SCOs, including the definition of LSA\nand SCOs, the determination of distribution of activity in LSA material or on SCO surfaces,\nmixing LSA and SCOs in a package, radiation level measurements, and various other aspects of\ntransporting LSA and SCOs.\nThere are many requirements, other than those addressed herein, imposed in the shipment of LSA\nand SCOs. The guidance represents one or more methods of demonstrating compliance with the\nregulatory requirements for LSA material and SCOs that have been found acceptable to NRC and\nDOT; however, additional methods may also be found to be acceptable with adequate\njustification.\niii NUREG-1608\n\n<<<PAGE 6>>>\n\n\n\n<<<PAGE 7>>>\n\nCONTENTS\nABSTRACT .............................................................. iii\nACKNOWLEDGMENTS ..................................................... x\n1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1\n2 BACKGROUND ........................................................ 2-1\n3 SURFACE CONTAMINATED OBJECTS .................................... 3-1\n3.1 Categorizing a Class 7 (Radioactive) Material as an sea ................ 3-1\n3.1.1 If a contaminated object is also activated, can it be categorized\nas an SCO? ............................................. 3-2\n3.1.2 Is there a contamination level below which an object does\nnot need to be categorized as an SCO or as radioactive\nmaterial, n.o.s.? .......................................... 3-2\n3.1.3 How should a contaminated object with a limited quantity of\nradioactive material be categorized? .......................... 3-2\n3.1.4 Must all radionuclides be individually accounted for, and\nis there an applicable sum or fractions rule which should\nbe applied in assessing compliance with the sea\ncontamination limits? ..................................... 3-3\n3.1.5 Are there any constraints on mixing SCOs with nonhazardous\nmaterials in a packaging? ................................... 3-3\n3.1.6 Can an object which might qualify as an sea-I be categorized\nand shipped as an SC0-11? ................................. 3-3\n3.2 Clarification of Terms Used in the sea Definitions .................... 3-3\n3.2.1 What is contamination? ................................... 3-4\n3.2.2 What is fixed contamination and non-fixed (removable)\ncontamination? .......................................... 3-4\n3.2.3 What are accessible surfaces and inaccessible surfaces for seas? ... 3-5\nv NUREG-1608\n\n<<<PAGE 8>>>\n\nContents\n3.3 Quantity-Based Method for Compliance With the SCO Definitions ......... 3 .. 5\n3.3.1 What is a practical method for categorizing an object as\nSCO for shipment under exclusive-use in a strong tight\ncontainer [using 49 CPR 173.427(b)(3)]? ...................... 3-6\n3.3.2 What methods should be used for categorizing an object\ncontaining greater than 1 A2 as SCO? ......................... 3-7\n3 .4 Determining Contamination Levels on Surfaces . . . . . . . . . . . . . . . . . . . . . . . 3-8\n3.4.1 What methods are acceptable for determining fixed and\nnonRfixed contamination on accessible and inaccessible\nsurfaces of SCOs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 -8\n3.4.2 When taking measurements, how can one distinguish\nfixed accessible contamination from total inaccessible\ncontamination? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8\n3.4.3 How can fixed alpha contamination be measured? ................ 3-9\n3.4.4 How can contamination level measurements be averaged? .......... 3-9\n3.4.5 How is wiping efficiency used in the determination of\ncontamination on package external surfaces and SCOs? .......... 3-10\n4 LOW SPECIFIC ACTIVITY MATERIAL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1\n4.1 Categorizing a Class 7 (Radioactive) Material as LSA .................. 4-1\n4 .1. 1 What general categories of materials are intended to be\nshipped as LSA? ......................................... 4-1\n4.1.2 Is there a contamination limit for an LSA material's surfaces? ....... 4-2\n4.1.3 When an unshielded LSA material exceeds 10 mSv/hr\n(1 rem/hr) at 3 m (9.9 ft), what is the proper shipping name? ....... 4-3\n4 .1. 4 Is there an object size below which collections of small,\ncontaminated objects may be categorized and shipped as LSA\nmaterial (as opposed to SCOs)? ............................. 4-3\n4 .1. 5 Can activated metals, or a radioactive material which is\nsolidified or absorbed on nonradioactive material, be\ncategorized as LSA-11? .................................... 4-4\nNUREG-1608 vi\n\n<<<PAGE 9>>>\n\nContents\n4 .1. 6 Can the mass of grout or binding agents used in or on\nan object be included in the LSA specific activity or\nunshielded dose rate determinations? . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4\n4 .1. 7 Can leach testing for disposal ( 10 CFR Part 61) substitute\nfor the LSA-III leach test? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4\n4.1.8 Is it acceptable to use representative samples in the\nLSA-111 leach test? ....................................... 4-5\n4.1.9 Is it necessary to leach test activated metals? .................... 4-6\n4.2 Clarification of Tenns Used in the LSA Definitions ..................... 4-6\n4.2.1 What is the intent of the terminology rubble, other\ndebris and activated material in the LSA-I definition? ............ 4-6\n4.2.2 What is the difference between distributed throughout\nand essentially uniformly distributer.I? ......................... 4-7\n4.2.3 What practical techniques can be used for demonstrating\nthe activity in an LSA material is distributed throughout\nor essentially uniformly distributed, as applicable? . . . . . . . . . . . . . . . 4-7\n4.2.4 Can compliance with NRC's \"Branch Technical Position\non Concentration Averaging and Encapsulation\" be used\nto demonstrate that a IJlixture of candidate LSA materials\nare distributed throughout or essentially uniformly\ndistributed, as applicable? .................................. 4-8\n4.2. 5 What is a combustible solid with respect to the conveyance\nactivity limit for LSA material of 100 A2? . . . . . . . . . . . . . . . . . . . . . . 4-9\n4.2.6 What was the misprint in NRC's and DOT's September 28, 1995,\nFederal Register final rules (60 FR 50292 and 60 FR 50248)\nregarding the tenns distributed throughout and essentially\nuniformly distributer.I? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10\n5 UNSHIELDED DOSE RATE LIMIT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1\n5. 1 Intent of the Dose Rate Limit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1\n5.1.1 Where does the unshielded dose rate limit apply? . . . . . . . . . . . . . . . 5-2\nvii NUREG-1608\n\n<<<PAGE 10>>>\n\nContents\n5.1.2 Do the possible effects ofredistribution of the LSA\nmaterial or SCOs in transport (and resultant loss of\nself-shielding) need to be assessed? ........................... 5-2\n5.1.3 Can liners (e.g., disposal containers), waste binders, or\nother packaging materials be considered in complying\nwith the dose rate limit? ................................... 5-2\n5.1.4 If slightly contaminated/activated materials are shipped\nin the same package as other LSA material, how should\nthe external dose rate be calculated and/ or measured for\nthese non-uniform sources? ................................. 5-3\n5.2 Quantity-Based Method for Compliance With the Dose Rate Limit ......... 5-3\n5 .2.1 What quantity of LSA material or SC Os in a package\ncan be assumed, without further analysis, to comply with\nthe dose rate limit? ....................................... 5-3\n5.2.2 For explicit demonstrations of compliance with the dose\nrate limits, which methods are acceptable? ...................... 5-4\n5.2.3 If package measurements and back-calculations to\nunshielded dose rates are used, how can account be\ntaken for the effects of the packaging (e.g., the\nsmoothing of radiation readings, and the masking\nof \"hot spots\")? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4\n6 PACKAGING AND SHIPPING REQUIREMENTS ............................. 6-1\n6.1 Mixing LSA Materials and SC Os Together or with Other\nHazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1\n6.1.1 What is the general rule for mixing LSA material\nand SC Os in a single package? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1\n6.1.2 What is the proper shipping name for a mixed\nLSNSCO package? ...................................... 6-2\n6.1.3 When a material meets an LSA material definition but\nalso the definition of another Hazard Class (e.g., corrosive\nliquid, n.o.s., PG I), how should the material be classified\nand prepared for shipment? ................................ 6-2\nNUREG-1608\nviii\n\n<<<PAGE 11>>>\n\nContents\n6.2 Pre-Shipment Processing of LSA Material and SCOs . . . . . . . . . . . . . . . . . . . 6-3\n6.2.1 How can accessible surfaces be converted into\ninaccessible surfaces? ..................................... 6-3\n6.2.2 How can non-fixed (removable) contamination be\nrendered fixed? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3\n6.2.3 Can grout or binding agents or encapsulating materials\nbe considered in LSA-specific requirements? .................... 6-3\n6.2.4 Is there a requirement to document the determinations\nwhich show compliance with regulatory requirements\nincluding categorization of a material or object as LSA\nmaterial or sea and the determination of unshielded\ndose rate? .............................................. 6-4\n6.3 Packaging Requirements for LSA Materials and SCOs .................. 6-4\n6.3. l What are the design requirements for a strong, tight\npackage? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4\n6.3.2 Can any LSA material or SCOs be shipped unpackaged\nor as its own packaging? .... , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4\n6.3.3 Could a shipper package and transport LSA material\ninside a packaging that would otherwise meet the definition\nof SCO? ............................................... 6-7\n6.3.4 What are the rules for continued use of NRC-certified\nType A LSA packages \"grandfathered\" by 10 CFR 71.52?\nIs exclusive-use required? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-7\n7 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1\nAPPENDIX A Regulatory Process for Categorizing Materials and\nObjects as LSA Material or SCOs and Selecting\nPackaging Options ...................................... A - 1\n1X NUREG-1608\n\n<<<PAGE 12>>>\n\nACKNOWLEDGMENTS\nThis guidance was jointly developed by the U.S. Department of Transportation and the\nU.S. Nuclear Regulatory Commission, with technical support from the Oak Ridge National\nLaboratory (ORNL).\nIn preparing the guidance, input was obtained from nuclear industry representatives, including\nNRC licensees, those shipping radioactive materials for the U.S. Department of Energy, and\npersonnel involved in auditing or inspecting the packaging and transport of low specific activity\nmaterials and surface contaminated objects.\nNUREG-1608 x\n\n<<<PAGE 13>>>\n\n1 INTRODUCTION\nLarge volumetric quantities of low-level radioactive waste (LLW) have historically been shipped\nas low specific activity (LSA) material. In addition, radioactive ores, plant maintenance and\noutage equipment, and U.S. Department of Energy (DOE) wastes have typically been categorized\nas LSA. The regulations take into account the inherent properties of LSA materials and surface\ncontaminated objects (SCOs), and allow for less-strict packaging requirements as compared to\nother radioactive materials, while retaining comparable levels of satety at lower costs.\nChanges to NRC regulations in Title 10 of the Code of Federal Regulations, Part 71, \"Packaging\nand Transportation of Radioactive Materials\" (NRC, 1996a), and to DOT regulations in Title 49\nof the Code of Federal Regulations, Part 172 - 178, \"Shippers General Requirements for\nShipments and Packaging\" (DOT, 1996) have changed the regulatory framework under which\nLSA materials are shipped. These revised regulations, which became effective April 1, 1996,\ngenerally make domestic regulations for the safe transportation of radioactive materials\ncompatible with requirements of the International Atomic Energy Agency's (IAEA) Safety Series\n6, Regulations for the Safe Transport of Radioactive Material, 1985 edition (as amended 1990)\n(IAEA, 1990a).\nUnder the previous regulations, the old LSA material category included as a subcategory,\nrequirements for SCOs. In contrast, under the revised rules, the scheme for shipping these\nmaterials has been refined such that SCOs are now defined as their own category. At first\ninspection, this differentiation between the two types of materials seems clear and definitive.\nHowever, the wording of the regulations, and practical considerations in characterizing,\ncategorizing, handling, packaging, and transporting these materials, result in some uncertainty as\nto consic;;tent, practical, and acceptable implementation of the revised requirements.\nUnder the revised regulations, it is expected that most equipment will be categorized for\nshipment as SC0-11, whereas most waste will be categorized as LSA-11. There will probably be\nmany exceptions to this generalization, including a variety of materials and objects whose\ncharacteristics (both physical and radiological) are uncertain or difficult to characterize.\nThis guidance is intended to assist both shippers and regulators in applying the regulatory\nrequirements for LSA material and SCOs properly. It should be recognized that no single\ndocument could address all issues related to the transport of these materials and objects.\nThis guidance, which is presented in the form of questions and answers, is provided in four\nsections addressing:\n• issues related specifically to SCOs (Section 3);\n• issues related specifically to LSA material (Section 4);\n• issues relating to determination of the dose rate 3 m (9.9 ft) from the unshielded\nmaterial, object or collection of objects (Section 5); and\n• issues relating to the preparations for shipment and the packaging of LSA material\nand SCOs (Section 6).\nIn addition, an appendix (Appendix A) provides a logic flow process, based on the domestic\nregulations (DOT, 1996; NRC, 1996), which may be used to guide the characterization and\n1-1 NUREG-1608\n\n<<<PAGE 14>>>\n\nIntroduction\ncategorization of materials and objects as LSA material and SCOs. This appendix also contains a\ntable which can be used to define packaging options available to shippers in the United States\nbased upon the results of the characterization guided by the logic flow diagrams. The questions\nasked and answered in Sections 3 through 6 of this guidance are also identified in the diagrams\npresented in the appendix.\nThis Guidance was published in draft form for public comment. NRC and DOT appreciate the\nefforts on the part of all contributors, and have attempted to address the comments to the extent\npracticable. However, comments that, in the opinion of NRC and DOT staff, were unclear,\ninaccurate, contradictory to regulatory requirements, or non-compelling, were not adopted.\nNothing contained in this guide may be construed as having the force and effect of NRC or DOT\nregulations, or as relieving any shipper or licensee from compliance with the requirements of\n10 CFR Part 71, 49 CFR Part 173, or any other applicable regulation.\nThe guidance describes one or more methods of demonstrating compliance with the regulatory\nrequirements for LSA material and SCOs that NRC and DOT have found acceptable. However,\nuse of these methods is not mandatory. Methods other than those described here may also be\nfound to be acceptable based on reseasoned argument, or other adequate justification. Shippers\nare reminded that it is their responsibility to be able to demonstrate that their methods satisfy\napplicable regulatory requirements.\nNUREG-1608 1-2\n\n<<<PAGE 15>>>\n\n2 BACKGROUND\nAlthough the new regulations for LSA material and SCOs are more prescriptive than were the\nprevious regulations, DOT and NRC personnel have not observed a major economic or practical\nimpact of the revised rules on the shipment of waste as LSA material or contaminated objects as\nSCOs. Specifically, experience shows that such activities have continued to take place in a safe\nmanner under the new rules.\nHowever, because of the more prescriptive nature of the new rules, many questions have been\nasked, and it was determined by DOT and NRC that guidance on the new LSA material and SCO\nrequirements would benefit both the regulated and the regulators.\nAreas of uncertainty in the revised regulations include:\n(a) (b) (c) (d) definitions, classification and categorization of materials and objects,\ndetermination of distribution of activity in LSA material or on SCO surfaces,\ndeterminations of the dose rate from the unshielded material or object, and\npreparation of materials and objects and selection of proper packaging for transport.\nMany of these are related to changes made in the regulations, where, in addition to providing a\ncategory for SCOs separate from LSA materials:\n(1) LSA materials are further divided into three subcategories (LSA-I, LSA-II, and LSA-III),\nand SCOs are further divided into two subcategories (SCO-I and SC0-11);\n(2) the LSA material subcategory definitions make distinctions between the terms essentially\nuniformly distributed and distributed throughout depending upon the subcategory of LSA\nmaterial;\n(3) specific activity limits for LSA material have been tied to each nuclide's Ai value, and\nhave increased substantially for most nuclides [the A2 quantity is the amount of normal\nform radioactive material which can be transported in a non-accident resistant, Type A\npackage - see, for example 49 CFR 173.433 (DOT, 1996)];\n(4) for SCOs~ the radioactive material contamination is distributed on the surfaces of objects\nthat are not themselves radioactive, and the definitions distinguish between fixed and\nnon-fixed (i.e., removable) contamination on accessible surfaces but combines them for\ninaccessible surfaces;\n(5) NRC certification of the package design for shipment of some LSA materials and SCOs\nis no longer required unless the dose rate from the unshielded material exceeds 10 mSv/h\n(1 rem/h) at 3 m (9.9 ft); and\n(6) a new set of packages, industrial packages (IPs), has been authorized for use with LSA\nmaterial and SCOs.\n2-1 NUREG-1608\n\n<<<PAGE 16>>>\n\n\n\n<<<PAGE 17>>>\n\n3 SURFACE CONTAMINATED OBJECTS\nThe previous regulations contained provisions for shipment of SC Os as a subset of LSA material.\nSCOs were included in the LSA material definition in the previous versions of both 10 CPR\n71.4 and 49 CFR 173.403, and they were transported using the proper shipping name\n\"Radioactive material, LSA.\" However, the previous regulations specified only limits for total\n(fixed plus non-fixed) contamination, did not specify accessible nor inaccessible surfaces, and\nallowed for averaging the contamination over a large area [i.e., 1 m2 (10.8 ft2)].\nSCOs are no longer defined as a subset of LSAmaterial (DOT, 1996; NRC, 1996a). SCOs have\ntheir own proper shipping name, \"Radioactive material, surface contaminated object,\" or\n\"Radioactive material, SCO;\" and they have their own United Nations identification number,\n\"UN29 l 3 /' as specified in the hazardous material table [ 49 CFR 172.101 (DOT, 1996)].\nThe SCO definitions [49 CFR 173.403 (DOT, 1996) and 10 CPR 71.4 (NRC, 1996a)] now\nspecify separate limits for fixed and non-fixed (removable) contamination on accessible surfaces,\nand a limit for fixed plus non-fixed contamination on inaccessible surfaces. Compliance with\neach of these limits is necessary for categorization of an item as an SCO. However, compliance\ndoes not necessarily imply the need for explicit measurements of the contamination levels, as\nfurther discussed herein. In general, objects that satisfy the SCO definition will not satisfy the\nLSA definition, and should not be shipped as such. However, there are some circumstances\nwhere it is appropriate to ship collections of small objects as LSA material (see Section 4.1.4), or\nto ship SCOs mixed with LSA material as LSA material (see Section 6.1).\nSection 3.1 provides guidance on materials which can be categorized as SCOs. Section 3.2\nclarifies some of the technical terms used in the SCO definitions. Section 3.3 provides specific\nguidance for complying with the sea definitions, based on the quantity of radioactivity in a\npackage. Section 3.4 provides guidance for determining contamination levels on surfaces.\n3.1 Categorizing a Class 7 (Radioactive) Material as an SCO\nCategorizing an object contaminated with Class 7 (radioactive) material as an SCO is an option\nfor transport as compared with categorizing the material as \"Radioactive material, n.o.s.,\" with\nan identification number of \"UN 2982.\" SCO means a solid object which itself is not\nradioactive, but which has Class 7 (radioactive) material distributed on its surfaces.\nCategorization as SCO provides some relief from the packaging requirements and\ncommunications requirements when compared with the alternative categorization of\n\"Radioactive material, n.o.s.\"\nObjects that are themselves radioactive (e.g., activated objects) and that are also contaminated\ncannot generally be categorized as SCO. The exception to this is discussed below. Objects that\nare radioactive and contaminated may be categorized as LSA material insofar as the requirements\nspecified in the LSA definition are complied with (see Section 4.1.2).\n3-1 NUREG-1608\n\n<<<PAGE 18>>>\n\nSurface Contaminated Objects\nIf a contaminated object is also activated to an average specific activity level less than 70 Bq/g\n(2 nCi/g)~see 49 CFR 173.403 (DOT, 1996)-the object itself is not classified as radioactive\nmaterial according to 49 CFR 173.403 (DOT, 1996); however, the presence of the contamination\non the object may require that it be classified as a Class 7 (radioactive) material. For such an\nobject, if the SCO definition is satisfied, the object should then be classified as Class 7, and\nshipped as an SCO.\nHowever, if a contaminated object is also activated to an average specific activity level in excess\nof 70 Bq/g (2 nCi/g), the object itself is classified as radioactive material according to 10 CPR\n71.4 and 49 CFR 173.403 (DOT, 1996; NRC, 1996a). In this event, it may not be categorized as\nan SCO since SCOs are, by definition [49 CPR 173.403 and 10 CPR 71.4 (DOT, 1996; NRC,\n1996a)], non-radioactive objects having radioactive-contaminated surfaces.\nInternational regulations (IAEA, 1990a) contain a threshold value for contamination, below\nwhich a nonradioactive object [i.e., an object having an average specific activity level less than\n70 Bq/g (2 nCi/g)] can be shipped without regard to the radioactivity [See clarification of\ncontamination in Section 3.2.1]. The contamination threshold value was inadvertently omitted\nfrom the 1996 DOT domestic regulatory revisions (DOT, 1989; DOT, 1996). Consequently, all\nobjects which are themselves not radioactive, but are slightly contaminated, could still be\nconstrued to qualify as SCO-I. DOT is currently addressing this issue.\nIn the interim: an object with external contamination may be considered to be excepted from\nclassification as Class 7 (radioactive) material if: (1) contamination when averaged over each 300\ncm2 (46.5 in2) of all surfaces is less than 0.4 Bq/cm2 00-5 µCi/cm2\n) for beta and gamma emitters\nand low toxicity alpha emitters, and is also less than 0.04 Bq/cm2 (10-6 µCi/cm2) for all other\nalpha emitters; and (2) the object itself has an average specific activity less than 70 Bq/g (2\nnCi/g).\nAny radioactive material that meets the requirements in 49 CPR 173.421, for excepted packages\nof limited quantities of Class 7 (radioactive) materials, can be shipped as \"Radioactive Material,\nexcepted package, limited quantity of material, UN2910.'' Note, however, that the activity per\npackage in a normal form shipment (such as a contaminated object) would be limited to 10·3 A2\nas given by Table 7 of 49 CPR 173.425. In such cases, there is no need to evaluate for\ncompliance with the SCO contamination limits.\nNUREG-1608 3-2\n\n<<<PAGE 19>>>\n\nSurface Contaminated Objects\nThe SCO limits for contamination apply to any 300 cm2 (46.5 in2) • There is no requirement to do\na sum of fractions (or \"unity\") rule.\nAn object could be categorized as SCO, even if the surfaces were contaminated to both the limit\nfor beta and gamma emitters and low toxicity alpha emitters, and to the limit for all other alpha\nemitters. Further, it could simultaneously have the contamination at the non-fixed (removable)\nlimit on accessible surfaces, the fixed limit on accessible surfaces, as well as the limit on\ninaccessible surfaces.\nSince the SCO limits are stated in terms of activity (i.e., a beta-gamma limit and an alpha limit),\nthere is no explicit nuclide dependence, and there is no need to sum or identify nuclide fractions\nfor complying with the SCO definition. However, for shipping papers and labels (if not excepted\nfrom labeling), the nuclides must be identified and listed in accordance with the \"95% sum of\nfractions\" rule in 49 CFR §§ 173.433 and 173.435.\nll_.•~tl•llll1illililllYjlllltlll\nGenerally, waste management considerations may affect this practice. Three examples of\npackages containing SCOs mixed with nonhazardous materials include: SCOs mixed with non-\nradioactive materia]s (e.g., binding agents such as grout, or paint), as a means to transform non-\nfixed (removable) contamination into fixed contamination; as a means to make an accessible\nsurface into an inaccessible surface; and as a means of adding structura] capability to the object to\nfacilitate transport.\nGenerally, the most appropriate category should be used to assure that response to any incidents\nis suitable for the materials present. However, for domestic transport, an SC0-11 has equivalent\npackaging requirements to an SC0-1 [49 CFR 173.427(b)(2), (b)(3) and (b)(4) (DOT, 1996)].\nFurther, since SC0-1 poses less of a contamination hazard than does SC0-11, categorization of an\nobject as SC0-11 rather than as SC0-1 is a conservative approach. It is permissible to categorize\nradioactive material to higher categorization levels and package and ship them accordingly. Thus,\nit is permissible to categorize and ship an object which meets the SC0-1 definition as an SC0-11.\nUsing a higher category for LSA materials may not be as straightforward, however, since the\nactivity distribution and other conditions of the higher category must be satisfied.\n3.2 Clarification of Terms Used in the SCO Definitions\n3-3 NUREG-1608\n\n<<<PAGE 20>>>\n\nSurface Contaminated Objects\nThe definition of SC0-1 and SC0-11 in 10 CFR 71.4 and 49 CFR 173.403 (DOT, 1996; NRC,\n1996a) contains several technical terms that are not explicitly defined, namely: contamination,\nboth fixed and non-fixed, accessible suiface, and inaccessible suiface. This section provides\nadditional clarification of the intent and meaning of these terms as used in the regulatory\ndefinitions. The terms apply to SCO' s as prepared for transport.\nFor the purpose of complying with the SCO definitions in the domestic transportation regulations\nonly (DOT, 1996; NRC, 1996a):\nContamination is the presence of a radioactive substance on a suif ace in\nquantities in excess of 0.4 Bq/cm2 (10·5 µCi/cm2\n, 22 dpmlcm2)for beta and gamma\nemitters and low toxicity alpha emitters or 0.04 Bq/cm2 (10-6 µCi/cm2\n, 2.2\ndpmlcm2\n) for all other alpha emitters.\nThis is consistent with the definition for contamination provided in the international regulations\n(IAEA, l 990a), although a similar definition is not currently included in the U.S. domestic\nregulations. DOT is currently considering addition of the contamination definition to 49 CFR\nPart 173.\nThis internationally-recognized lower limit for contamination serves a function in transport\nregulations comparable to the limit of 70 Bq/g (2 nCi/g) in the definition of radioactive material\n[ 49 CFR 173 .403 (DOT, 1996)]; i.e., materials having specific activities less than this limit are\nbelow the scope of the hazardous material regulations. A definition of contamination is needed\nin order to properly utilize the SCO category because the radioactive material definition of 70\nBq/g (2 nCi/g), which is based on an activity per unit mass, is not readily or directly applicable to\nSCOs. For nonactivated objects, dividing the activity in the contamination by the mass of the\nnonactivated object (to determine whether the object as a whole should or should not be defined\nas radioactive material) is generally not appropriate because it opens the possibility for a massive\nobject with significant amounts of contamination on its surfaces falling below the regulatory\nthreshold definition of radioactive material [i.e., specific activity would be less than 70 Bq/g\n(2 nCi/g)]. This situation is not consistent with the intent of the regulatory exemption limit and\nshould be avoided.\nFor the purposes of complying with SCO definitions:\nFixed contamination is contamination that cannot be removed by the wipinf procedure\ndefined in 49 CFR 173.443, to a detection level of 0.4 Bq/cm2\n( 10-5 µCi/cm ) for beta and\ngamma emitters and low toxicity alpha emitters, or 0.04 Bq/cm2 ( 1 o-6 µCi/cm2) for all\nother alpha emitters. Any other contamination is non-fixed contamination.\nNUREG-1608 3-4\n\n<<<PAGE 21>>>\n\nSurface Contaminated Objects\nAlthough used in the definition of SCOs, there are no specific regulatory definitions of fixed\ncontamination or non-fixed contamination. Therefore, other regulatory requirements [e.g., 49\nCFR 173.443 (DOT, 1996)] have been considered in striving to develop consistent definitions.\nSpecifically, 49 CFR 173.443(a)(l) describes a method for wiping a surface and determining the\nlevel of non-fixed (removable) contamination available from that surface. The text of 49 CFR\nl 73.443(a)(l) reads, in part, that the process for determining the level of non-fixed (removable)\ncontamination consists of \"wiping an area of 300 square centimeters· of the surface concerned\nwith an absorbent material, using moderate pressure, and measuring the activity on the wiping\nmaterial. Sufficient measurements must be taken in the most appropriate locations to yield a\nrepresentative assessment of the non-fixed contamination levels.\"\nFor the purposes of complying with SCO definitions:\nAn accessible suiface is any suif ace which can readily be wiped by hand, using standard\nradiation-measuring techniques. Any other suif ace is an inaccessible surface.\nThe accessible surface could be contacted if the packaging is removed by an accident. Thus, re-\norientation of the SCO should be considered in identifying the accessible surface. However, a\nshipper does not need to consider damage to the object itself in an accident. For example, the\nbottom, or top, of an object would be accessible, but surfaces which must be reached by probing\nsmall openings would be inaccessible. A good rule of thumb is that, if a 300 cm2 (46.5 in2\n) area\ncould be reached by a person's hand, it is an accessible surf ace. The phrasing, \"by hand\" is not\nmeant to discourage use of as low as is reasonably achievable (ALAR.A) tools such as telescopic\nsampling instruments. The phrasing, \"standard radiation-measuring techniques,\" is intended to\nimply practices similar to those used for complying with package contamination limits in 49 CFR\n173.443.\nNote that this guidance would permit some objects, such as a tank, or a long 6 in. diameter pipe,\nto have some inaccessible surfaces that are readily measured/swiped. It is generally good\npractice to seal off the ends of pipes or tanks, such that a shock to the object could not result in\ncontamination being easily released through the openings.\n3.3 Quantity-Based Method for Compliance With the SCO Definitions\nAlthough pre-shipment determinations are required to demonstrate compliance with the\napplicable SCO definition, the regulations do not require measurements of contamination and/or\nradiation levels as the only means of accomplishing the determinations. Alternate methods or\ncombinations of methods may be used to demonstrate compliance. These methods may\ninclude-in addition to measurements--calculations, reasoned arguments, and reference to\nprevious shipments of similar materials or objects (see section 3.4.1). This section describes a\nreasoned argument approach to categorizing SCOs.\nThe level of detail in these determinations is expected to be commensurate with the potential\nhazard that the contamination represents. The potential hazard is based on the quantity (i.e.,\nactivity) and radio toxicity of the Class 7 (radioactive) material to be shipped, and the\n3-5 NUREG-1608\n\n<<<PAGE 22>>>\n\nSurface Contaminated Objects\ncombination of these two factors is associated with the relevant multiple or fraction of Ai, of the\ncontaminants involved. Therefore, the first step in any shipment should be to determine the Ai\nfraction in the package in accordance with 49 CFR 173.433.\nFor an SCO, the Ai fraction would typically be determined by analyzing representative swipes of\nthe accessible surface, gross gamma counts, the total surface area, and assuming the fixed and\ninaccessible contamination had a similar radionuclide distribution from a previously determined\nfacility-specific sample data base. The techniques for determining radionuclide content used in\nthe previous regulations remain acceptable under the revised regulations (note, however, that the\nnumber of nuclides in the Table of A/Ai values has increased, and the values have changed).\nIt is possible to make SCO determinations in a manner consistent with 10 CPR Part 20\nrequirements to maintain occupational exposures as low as is reasonably achievable (ALAR.A).\nIn practice, NRC and DOT anticipate that almost all SCO packages will contain less than 1 Ai\nquantity, and therefore qualify for shipment in strong-tight containers (STCs) pursuant to 49 CPR\n173.427(b)(3). A reasoned argument could be used to categorize the great majority of these\ncandidate SCOs, without the need for detailed, quantitative measurement of fixed, accessible\ncontamination or total (fixed plus non-fixed) inaccessible surface contamination. Both the beta-\ngamma Ai fraction and the alpha A2 fraction must be determined. The materials characterized\nusing this reasoned argument would be shipped as \"Radioactive - SCO.\"\nDemonstration of all of the following 4 conditions can be used to categorize a radioactive\nmaterial as an SC0-11. It is expected that these conditions would allow categorization of a great\nmajority of candidate SCO materials as SCO-II, without the need for detailed, quantitative\nmeasurement of fixed, accessible contamination or total inaccessible surface contamination.\n(1) (2) (3) ( 4) The shipment of the SCO-II is made pursuant to 49 CFR 173.427(b)(3), for domestic,\nexclusive-use transport of SCOs in strong-tight containers (STCs). Note that this requires\nthat the radioactive material in the package totals to less than 1 A2 quantity as determined\nusing the ","truncated":true,"body_characters":126059}