{"operation":"document","citation":"08-0079","title":"Washington Closure Hanford — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-07-09","effective_on":null,"summary":"08-0079 response to Washington Closure Hanford concerning 173.427, 173.441.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0079.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0079.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0079","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080079.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave.. S.E\nWashington. DC 20590\nJUL 19 2DO8\nMr. G.J. Borden\nWashington Closure Hanford\n2620 Fermi Avenue\nRichland, WA 99354\nRef. No.: 08-0079\nDear Mr. Borden:\nThis responds to your letter dated February 26,2008 requesting clarification of the\nHazardous Materials Regulations (HMR; Parts 171 - 1 80). Specifically, you ask for\nclarification on describing Class 7 (radioactive) material as Low Specific Activity (LSA)\nmaterial. Your questions are paraphrased and answered as follows:\nQ1. Is it appropriate to mix LSA types and classify the aggregate as the highest\n. class of material?\nAl. It is acceptable to mix LSA types and to classify the aggregate at the highest\nclassification of material, provided (emphasis added) that the individual types are\nproperly classified. Each constituent must meet the appropriate LSA material\ndefinition and meet the regulatory requirements for that classification. Also, since\nyou are dealing with items with varying dose rates, when commingling these\nmaterial types, care must be taken to ensure compliance with the requirement in\n§ 173.4 1 1 that there be no significant increase in the radiation levels at the\nexternal surfaces of the package under routine conditions of transport.\nIn your second example, it is not clear why you would choose to return items\nclassified as LSA-I1 material to the soil mixture when they could be shipped\nseparately in an Industrial Package Type 2 (IP-2) and the soil could then be\ntransported in an Industrial Package Type 1 (IP-1).\nIn your third example, you indicate that the metal items in the soil have high dose\nrates (several orders of magnitude higher than the soil). In order for these high\ndose rate items to be shipped as LSA-I1 material, not only must they meet the\nLSA-I1 material definition with an average specific activity of less than 1 A2 /g,\nbut also the external radiation level from the unshielded material (the metal items)\n\n<<<PAGE 2>>>\n\n42: A2: must not exceed 10 mSv/h (1 remh) at 3 meters fiom the unshielded material (see\n5 173.427(a)(I)). Compliance with this requirement does not allow a person to\ntake credit for shielding provided by the packaging or the soil. The inherent\nproperty of the material must be limited so that even without any shielding, the\ndose rate would not exceed the limit.\nAs there may be multiple high dose rate items in some of your packages, you\nshould show that if all the high dose rate items that might be in a single package\nwere aggregated into the worst-case configuration (such that it would result in the\nhighest dose rate at 3 meters), the resulting configuration would not exceed 10\nmSv/h (1 rem/h) at 3 meters-fiom the unshielded material, without taking any\ncredit for shielding provided by the soil or packaging.\nFor those items that do qualitjl as LSA-I1 material, they must be properly secured\nsuch that the package limits are still met and there is not a significant (20%)\nincrease at any external surface of the package during routine conditions of\ntransport (see 5 173.41 1).\nIs it acceptable to use the criteria in NUREG1608 Section 4.2.3 to determine\nif a material has the radioactivity distributed throughout for material that\nmay have significant variations in dose?\nThe approach given in NUREG-1 608 section 4.2.3, while generally appropriate,\nmay not be appropriate when there are significant variations in dose. Since your\nexamples deal with a mixture of soil and activated metal items, section 4.2.;4 of\nNUREG-1 608, which addresses mixtures of materials, should be considered. That\nsection notes that materials which the Nuclear Regulatory Commission (NRC)\n\"Branch Technical Position on Concentration Averaging and Encapsulation\"\nrecommends should be considered as discrete items for low-level radioactive\nwaste (LLW) classification should also be considered discrete items and be\nevaluated individually against the LSA definitions, as appropriate. Section 3.3.1\nof the Branch Technical Position states that a mixture of activated metal items\ncontaining primary gamma-emitters (such as Co-60 that you cited as the primary\nisotope of concern) should be averaged only if the individual items are within 1.5\nof the respective averaged concentration value for each nuclide.\nYour first two examples of localized \"hot spots\" would indicate the need for a\ncloser examination of the situation to determine how the activity is distributed\nthroughout the material. The analysis that shows less than a factor of 10\ndifferences between sections that are no greater than 0.1 m3 should be\nsupplemented with consideration of the activity distribution of the activated\nmetal. As the metal items are known discrete pieces, they should be considered\nseparately from the soil and not averaged over a 0.lm3 volume (which would have\nthe soil composing more than 3 ft3 of the 3.5 ft3). The potential for multiple metal\nitems in close proximity must also be considered.\n\n<<<PAGE 3>>>\n\nQ3: A3: Q4: A4: Your third example relies on the soil to provide shielding around the activated\nmetal items in order to meet the limits of Q 173.41 1. This is only appropriate if\nthe resulting package can be shown to meet all of the applicable requirements.\nFirst, as discussed above, the metal items in a package must have an aggregate\nunshielded dose rate that does not exceed 10 mSv/h (1 r e d ) at 3 meters. Also,\nas stated in Q 173.41 1(b)(2) for an IP-2 package, there should be no significant\nincrease in the radiation levels when subjected to normal conditions of transport\n(see Q 173.410(f)) or the free drop test of Q 173.465(c). It is not clear if the metal\nitems would qualify as LSA-I1 material or if the package arrangement you\ndescribe would meet these requirements.\nIf dose rate is a determining factor in \"distributed throughout\", what is the\napplicable guidance? Is the factor of 10 in NUREG-1608 for specific activity\nalso applicable to dose rate? Or is meeting the limitations of 8 173.441 the\nonly concern regarding dose rates?\nDose rate is not a specific determining factor in \"distributed throughout,\" except\nthat it should be used to inform the analysis of the distribution of specific activity\nas described above.\nIn addition to Q 173.441 regarding dose rates, as discussed above, 8 173.427(a)\nrequires a limit of 10 mSv/h (1 r e d ) at 3 m from unshielded LSA material.\nAlso, as discussed above, for an IP-2 package, Q 173.41 l(b)(2)(ii) requires that\nthere not be a significant increase in the radiation levels during routine conditions\nof transport.\nCan a determination of \"distributed throughout\" (assessed through\nmeasurements, calculations or process knowledge) is identified in NUREG-\n1608 Section 4.2.3 be made on a \"bounding case\" based on a worst case\nscenario from the same waste stream covering multiple shipments, or does a\nseparate evaluation need to be made for each individual shipment?\nIt is the shipper's responsibility to properly class and describe a hazardous\nmaterial in accordance with the HMR for each shipment. A \"bounding case\"\nevaluation may be sufficient, provided the determination is adequately justified as\nbeing applicable to the individual shipments. Sufficient information would be\nneeded to assure that the waste stream is uniform enough such that each\nindividual shipment fits the bounding conditions.\nIn the example you provided, it is not clear what knowledge you would have\nabout the distribution of metal pieces within the soil to be able to bound the\nnumber of pieces per package. Nor is it clear how uniformity of the soil or the\nmetal items can be assumed.\nYour questions reference the document NUREG- 1608. Note that NUREG- 1608\n(RAMREG-003) was intended as general guidance to assist in applying the regulatory\n\n<<<PAGE 4>>>\n\nrequirements for LSA material and SCOs that were introduced in 1996. However, no\nsingle document can address all issues related to the transport of these materials and\nobjects. Furthermore, nothing in that document should be construed as having the force\nand effect of DOT regulations, or as relieving any shipper from compliance with the\nrequirements of 49 CFR Part 173 or any other applicable regulation.\nAlso, please note that if any fissile nuclides are present, any shipments of this material\nmust meet at least one of the paragraphs (a) through (f) of 5 173.453, as non-excepted\nfissile material is not permitted to be shipped as LSA material.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\n.-- f,'\nSusan Gorsky\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 5>>>\n\nFEB 2 6 2008\nU.S. Department of Transportation\nOffice of Hazardous Materials Standards (PHH-10)\nOffice of Hazardous Materials Safety\nPipeline and Hazardous Materials Safety Administration\nMr. John Gale\nChief, Standards Development\nEast Building, 2nd Floor\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nSubject: LOW SPECIFIC ACTIVITY SHIPMENT CLARIFICATION\nDear Mr. Gale:\nWashington Closure Hanford LLC (WCH) is performing remediation activities at radioactive\nwaste burial grounds. This remediation involves excavating contaminated soil and miscellaneous\ndebris from the burial grounds and packaging the waste for shipment. The waste consists\nprimarily of soil contaminated with activation and fission products meeting the definition of Low\nSpecific Activity (LSA)-I or LSA-11, as well as some activated metal meeting the definition of\nLSA-I1 material. Due to the presence of fission products in the soil, the activated metal can have\na significantly higher dose rate than the soil for a similar specific activity. The activated metal\npieces are usually small steel or aluminum components less than 0.5 it3 and approximately 2\npounds (e.g., hollow perforated pipe 6\" x IS\"), and the primary shipment method is transported\nin a 2 0 - ~ d ~ meeting all applicable packaging requirements. The packaging system is made of\ncarbon steel with no added shielding material. The primary isotope of concern is Colbalt-60.\nThe aggregate load may exceed an A2 value. Currently this practice takes place on a closed\ngovernment installation to which the public does not have access. However, WCH will soon be\napplying these same practices to \"in commerce\" shipments and would like the U. S. Department\nof Transportation clarification regarding the following questions prior to proceeding:\n1. Is it appropriate to mix LSA types and classify the aggregate as the highest classification\nof material?\nExample 1:\nSoil that meets the definition of LSA-I is co-mingled with pieces of activated metal that meet\nthe definition of LSA-I1 material. Rather than attempting to remove the activated metal, the\nentire mass is classified'as LSA-11.\nWashington Clos~~re Hanford 2620 Ferrni Avenue\nRichland, WA 99354\ntel (509) 375- 4640\nfax (509) 375- 4644\n\n<<<PAGE 6>>>\n\nMr. Gale\nPage 2 FEB 2 6 2008\nExample 2:\nActivated metal items are removed from soil that meets the criteria for LSA-I for\ncharacterization. The activated metal items are characterized as LSA-I1 material, returned to\nthe soil, and the entire mass is classified as LSA-11.\nExample 3:\nActivated metal items are removed from soil that meets the criteria for LSA-I for\ncharacterization. These removed metal items were identified due to high dose rate thus\nactivities of these metal items can be several orders magnitude higher than the contaminated\nsoil. The activated metal items are characterized as LSA-11 material, returned to the soil, and\nthe entire mass is classified as LSA-11.\nIt is WCH's understanding that these examples would be acceptable based on the following:\nAttached e-mail from Fred Ferate to Greg Borden dated June 12,2007,\nNUREG-1608 Section 4.2.3, which allows the use of the U.S. Nuclear Regulatory\nCommission branch Technical Position, which states in Section 3.3, \". .. in determining the\nclassification of such a mixture, it is always permissible to conservatively base the mixture\nclassification on the highest classification associated with any piece, section, or component\nwithin a disposal container or liner.\"\n2. Is it acceptable to use the criteria in NUREG-1608 Section 4.2.3 to determine if a material\nhas the radioactivity distributed throughout for material that may have significant\nvariations in dose?\nExample 1:\nSoil and activated metal are co-mingled in a package for disposal. When the container is\ndivided into sections no greater than 0.1 m3, no two sections have a difference in specific\nactivity that is greater than a factor of 10. However, the pieces of activated metal may create\nlocalized \"hot spots\" where the dose rate is greater than a factor of 10 more than areas with\nno activated metal.\nExample 2:\nSoil and activated metal are co-mingled in a burial ground. When excavated, the activated\nmetal is separated for characterization (this activated metal is identified by their significant\nhigher dose rate), and once characterized, the activated metal is returned to the soil. When\nthe container is divided into sections no greater than 0.1 m3, no two sections have a difference\nin specific activity that is greater than a factor of 10. However, the activated metal has a dose\nrate that is greater than a factor of 10 more than the soil.\nExample 3:\nSoil and activated metal are co-mingled in a burial ground. When excavated, the activated\nmetal is separated for characterization, and once characterized, the activated metal is returned\nto the soil. The activated metal has a dose rate which if placed directly against the side of the\npackaging would result in a dose rate greater than 200 mremlh on contact. To meet the dose\nrate limits, the item is strategically placed in the center of the soil so it is shielded and the\nresulting dose rate meets all of the limitations of 49 CFR 173.441. When the container is\n\n<<<PAGE 7>>>\n\nFEB 2 6 2008\nMr. Gale\nPage 3\ndivided into sections no greater than 0.1 m3, no two sections have a difference in specific\nactivity that is greater than a factor of 10. However, the activated metal has a dose rate that is\ngreater than a factor of 10 more than the soil.\nIt is WCHs understanding that these examples would be acceptable based on the following:\nThe language in NUREG-1608 Section 4.2.3, in which the determination of \"distributed\nthroughout\" is based on specific activity and not dose, and\nThe language in TS-G-1.1 section 226.7, which states:\n\"In addition, LSA-I1 could include many items of activated equipment from the\ndecommissioning of nuclear plants. Since LSA-11 materials could be available for\nhuman intake after an accident, the specific activity limit is based upon an assumed\nuptake by an individual of 10 mg. Since the LSA-I1 materials are recognized as being\nclearly not uniformly distributed (e.g., scintillation vials, hospital and biological\nwastes, and decommissioning wastes), the allowed specific activity is significantly\nlower than that of LSA-III. The factor of 20 lower allowed specific activity as\ncompared with the limit for LSA-111 compensates for localized concentration effects\nof the non-uniformly distributed material.\"\nThis would indicate that the potential for some discrepancy in material was accounted for in\nthe development of the limits for LSA-I1 material.\n4\n3. If dose rate is a determining factor in \"distributed throughout\", what is the applicable\nguidance. Is the factor of 10 in NUREG-1608 for specific activity also applicable to dose\nrate? Or is meeting the limitations of 49 CFR 173.441 the only concern regarding dose\nrates?\n4. Can a determination of \"distributed throughout\" (assessed through measurements,\ncalculations, or process knowledge) as identified in NUREG-1608 Section 4.2.3 be made\non a \"bounding case\" based on a worst case scenario from the same waste stream\ncovering multiple shipments, or does a separate evaluation need to be made for each\nindividual shipment?\nExample:\nBased on available data, a piece of activated metal with the highest activity is evaluated with\nthe activity of the soil in accordance with Section 4.2.3. If these are within a factor of 10, all\nshipments are considered to be distributed throughout, until or unless data are obtained that\n\n<<<PAGE 8>>>\n\nFEB 2 6 2008\nMr. Gale\nPage 4\nwould change that assumption (e.g., a piece of activated metal is found that is \"hotter\" than\nthe bounding case evaluated).\nIf you have any questions regarding this inquiry, please feel free to contact me at (509) 528-3139.\nSincerely,\nG. J. B den, ubject Matter Expert s\nWaste ~Zrvices/Environrnental protection\nAttachment: e-mail from Fred Ferate to Greg Borden dated 06- 12-2007\ncc: J. J. Waring (RL) L1-02, wla\nD. W. Claussen (RL) A5-17, w/a\n\n<<<PAGE 9>>>\n\nAttachment\ne-mailfiom Fred Ferate to Greg Borden, dated June 12,2007\n\n<<<PAGE 10>>>\n\nBickford. Joan A\nFrom: Borden, Gregory J\nSent: Monday, February 25,2008 2:14 PM\nTo: Bickford, Joan A\nSubject: FW: Information Center Comments/Questions\nAttachments: IVUREG 1608 Chapter Apdf\nNUREG 1608\napter 4.pdf (1 ME\n----- Original Message-----\nFrom: fred.ferate@dot.gov [mailto:fred.ferate@dot.gov]\nSent: Tuesday, June 12, 2007 3:09 PM\nTo: Borden, Gregory J\nCc: erin.jarman@dot.gov\nSubject: FW: Information Center Comments/Questions\nHello Mr. Borden,\nSome of the sources I would look to for information to answer your questions are\na) the definitions of LSA-I and LSA-11;\nb) explanatory material in TS-G-1.1, \"Advisory Material for the IAEA Regulations for the\nSafe Transport of Radioactive Material\"\n(downloadable at\nhttp://www-pub.iaea.org/MTCD/publications/PDF/PubllO9~scr.pdf).\nc) the somewhat out-of date NUREG-1608, \"Categorizing and Transporting Low Specific\nActivity Materials and Surface Contaminated Objects\" (I have attached a pdf copy of\nChapter 4). NUREG-1608 was published jointly by the NRC and DOT in 1997.\nYou say that separately the soil can be classified as LSA-I and the activated metal as\nLSA-11. You also say that in some cases the specific activity for the activated metal may\nexceed an order of magnitude difference (which I take to mean a factor of 10) in activity\nfrom the specific activity of the soil, and the activated metal (reactor\ncomponents) are randomly distributed in the soil.\nParagraph 226.13 of TS-G-1.1 claims that the use of the phrase \"distributed throughoutn\n(found in the definitions of LSA-I (up to 30 times the exemption activity concentrations)\nand LSA-11) \"puts no requirement on how the activity is distributed throughout the\nmaterial.\"\nIt goes on to say that it is still important to note that the concept of LSA is not very\nmeaningful if the activity is confined to a small portion of the total volume.\nFrom your description it appears that the activity in your shipments is not confined to a\nsmall portion of the total volume, even though within that volume there will be sometimes\nbe spikes in the local specific activity, so I would say that conceptually you are still\nclearly within the intended realm of low specific activity material.\n1. You ask whether it is permissible to utilize the total mass and activity of the\ncontainer including both the soil and activated components to determine the LSA\nclassification as long as the individual items all meet the definition of LSA.\nGenerally the mass of the packaging is not to be included when calculating the average\nspecific activity (although I don't think this is what you were asking).\nI think you are saying \"Can I put everything - soil and whatever activated components are\npresent - in the container, add up the total activity, determine the total mass of the\ncontents of the container, and divide the former by the latter to determine an average\n1\n\n<<<PAGE 11>>>\n\nactivity per unit mass, and then see what LSA category that falls in?\" Assuming that that\nis your question, I will try to answer that below:\nParagraphs 226.14 and 226.15 of TS-G-1.1 suggest a method for assessing the average\n[specific] activity of LSA material. That is to imagine the material in the container\ndivided into ten parts of equal size and to compare specific activities of the parts; if\nthe average specific activities of the parts differ by no more than a factor of 10, they\nsuggest, this \"would cause no concern.\" I take this to mean that in that case you could\njust average the averages for the ten parts to determine the average specific activity for\nthe entire contents of the container, and from there select the LSA category.\nAdditional guidance is found in paragraph 4.2.3 of NUREG-1608. There it says that it is\npermissible to apply qualitative techniques for LSA materials in quantities less than 1\nA2, and to apply more quantitative techniques if you have more than 1 A2. It goes on to\nsay that \"if it is known that the material has a highly-stratified or significantly\nnon-uniform distribution, . . . , a more rigorous assessment will\nbe required.\" It goes on to describe a technique, if you have more\nthan an A2 quantity, similar to, but somewhat more restrictive, than that described in TS-\nG-1.1 to determine the average specific activity of the material in the container. The\nNUREG-1608 criterion (which is essentially our DOT criterion) is to conceptually divide\nyour material into AT LEAST ten parts, with each part having a volume NO GREATER THAN\nO.lm3. To be \"distributed throughout,\" specific activity differences between any two\nvolumes should not vary by more than a factor of 10.\nIt sounds to me like you can't always be sure that the average specific activities of the\nten parts will never differ by more than a factor of 10. In this case I suggest that the\nmore conservative and more appropriate path would be to ship all the material as LSA-11.\n2. I think my last statement answers your question 2. We at DOT have no objection to\nyour shipping a hazardous material in such a way as to offer a greater level of safety.\nIt is true that in some cases your activity is still not \"distributed throughout,\" in the\nquantitative sense described above (and so could not be called LSA-I or LSA-11); however,\nI think that it would less dangerous to ship all the material as LSA-I1 than to ship part\nas LSA-I and part as LSA-11. Thus my suggestion is that, unless you can show that a\nparticular shipment is definitely LSA-I, it would be better to ship it as LSA-11.\n3. You ask if the answers to your other questions are dependent on the relationship to an\nA2 value.\nThe A2 value plays an important role in determining the type of package you must use to\nship the material. 49 CFR 173.427(b)(4) allows you to ship domestically less than an A2\nquantity of LSA material (under exclusive use) in a packaging which meets the requirements\nof 173.24, 173.24a, and 173.410. If you have an A2 quantity or greater, LSA-I1 must now\nbe shipped (see 173.427(b)(1) and the corresponding Table 6) in a Type IP-2 packaging.\nAccording to 173.411(b) (2), an IP-2 packaging must be such that the loaded package\nsatisfies the performance requirements in 173.465(c) and (d); i.e., the Type A package\ndrop test and stacking test.\n(Note, however, that 173.411(b) (6) allows the use of an appropriate IS0 freight container,\nand 173 -411 (b) (7) allows the use of an. appropriate IS0 IBC, as a Type IP-2 packaging.\nThis comes with the caveat of 173.41l(c), which requires the availability of documentation\nshowing that the packaging being used satisfies the stated performance\nstandards.)\nWhat I have given you is my opinion, based on what you have told me, and my interpretation\nof the regulations. There is leeway for differences in judgment, and you are more\nfamiliar with your operations than I.\nI hope this helps.\nSincerely,\nFred Ferate, Ph.D., CHP\nPHMSA/Radioactive Materials Branch\nU.S. Department of Transportation\nEast Building, 2nd Floor, PHH-23\n1200 New Jersey Avenue, S.E.\n\n<<<PAGE 12>>>\n\nWashington, D.C. 20590-0001\nPhone: 202-366-4498\nFax : 202-366-3753\n- - - - - Original Message-----\nFrom: INFOCNTR <PHMSA>\nSent: Tuesday, June 12, 2007 11:24 AM\nTo: Ferate, Fred <PHMSA>\nSubject: FW: Information Center Comments/Questions\nFred,\nDo you think there is any chance that you could look at this e-mail and see if you can\nassist this gentleman? Several of us have looked at what he is asking and this is so far\ninto RAM that we think it is a little over our heads. So, I figured I would get your\ninput. I don't mean to dump this on you, but these questions seem a little more technical\nthan what we typically handle with radioactives over here. Let me know if you are too\nbusy or cannot help and I will bark up another tree. Thank you so much for looking at it.\nErin Jarman\nHMIC\n----- Original Message-----\nFrom: gjbordenewch-rcc-com [mailto:gjborden@wch-rcc.com]\nSent: Monday, June 11, 2007 12:26 PM\nTO: INFOCNTR <PHMSA>\nSubject: Information Center Comments/Questions\nBelow is the result of your feedback form. It was submitted by Greg Borden (gjborden@wch-\nrcc.com) on Monday, June 11, 2007 at 12:26:06.\nEmail : g j borden@wch-rcc . com\nName: Greg Borden\nCategory: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 -\n173.476)\nOrganization: Washington Closure, LLC\nStreet: 2620 Fermi Avenue\nCity: Richland\nState: Washington\nZip Code: 99354\nPhone: 509 531 0750\nFax: 509 373 4130\nComments: My company is involved in the remediation of past practice radioactive waste\nburial grounds. The waste being shipped is generally soil, with activated reactor\ncomponents randomly distributed in the soil. The specific activity of the soil is\nrelatively consistent (deviations are well less than an order of magnitude). Generally\nthe material is excavated and shipped together without any segregation in large (15-25\ncubic yard) containers.\nThe soil meets all of the definitional and other requirements for classification as LSA 1\nmaterial.\nThe activated metal meets all of the definitional and other requirements for\n3\n\n<<<PAGE 13>>>\n\nclassification as LSA 2 material.\nIn some cases the specific activity for the activated metal may exceed an order of\nmagnitude difference in activity from the specific activity of the soil.\nThe total activity of the containers is usually (-85-9088 of the time) less than an A2\nquantity.\n1 have the following three cpestions regarding the classification of these shipments:\n1) Is it permissible to utilize the total mass and activity of the container including\nboth the soil and activated components to determine the LSA classification as long as the\nindividual items all meet the definition of LSA?\n2) Is it permissible to classify the combined load in accordance with the highest\nclassification of any individual item (i.e., if the soil was\nLSA-1 and the activated metal LSA-2, the total load would be classified as LSA-2).\n3) Are the answers to these questions dependent on the relationship to an A2 value?\nIf you could please respond in an e-mail, I would appreciate it\nThanks for the assistance.\n\n<<<PAGE 14>>>\n\n4 .LOW SPECIFIC ACTIVITY MATERIAL\nThe previous regulations contained provisions for shipment of LSA material. While the specific\nactivity limit allowed in LSA material was significantly lower for essentially all radionuclides,\nthere was no upper limit to the amount of LSA material that could be shipped in a non-accident\nresistant package. The LSA limits in the previous rules were basically: 0.1 pCi/g for nuclides\nwith an A, 5 0.05 Ci (most alpha emitters); 5 pCi/g if 0.05 < A, 5 1 Ci (i.e., mixed fission\nproducts, Sr-90, Cm-242, Pb-2 10, Po-2 10, Pu-24 1, Ra 223, Ra-224, and uranium isotopes); or\n0.3 mCi1g for nuclides with an A, greater than 1 Ci (most gamma emitters).\nThe new limits are tied, on a nuclide-specific basis, to the A, values. In addition, the permissible\nconcentration for almost all nuclides has more than doubled under the widely-applicable LSA-I1\nsolids limit of lo4 AJg. For example, the previous limit for Co-60 was 0.3 mCi/g, whereas the\nLSA-I1 limit is now 1.08 mCi1g'. Similarly, the previous limit for Sr-90 was 5 pCi/g, whereas the\nLSA-I1 limit is now 270 pCiIg. And the previous limit for Pu-239 was 0.1 pCi/g, whereas the\nLSA-I1 limit is now 0.54 pCi/g.\n.LSA material has been divided into groups in the 1996 domestic regulations (DOT, 1996; NRC,\n1996a). It has retained its own proper shipping name and United Nations identification number,\nUN2912, in the hazardous material table [49 CFR 172.101 (DOT, 1996)l. Specific activity\nlimits for the LSA material category are now specified for three different subcategories (i.e.,\nLSA-1;'LSA-11, and LSA-111), which are explicitly related to the 4 of the material involved.\nFinally, the LSA definitions now distinguish between two types of distribution of activity in the\nmaterial, essentially uniformly distributed (used in the definitions of LSA-I and LSA-111) and\ndistributed throughout (used in LSA-I1 and LSA-111).\nSection 4.1 provides guidance on grouping materials as LSA-I, LSA-11, or LSA-111. Section 4.2\nclarifies some of the technical terms used in the LSA definitions, including specific guidance for\ncomplying with the distribution of radioactivity in the LSA material.\n4.1 Categorizing a Class 7 (Radioactive) Material as LSA\nShipping a Class 7 (radioactive) material as LSA material is an option to shipping the material as\n\"Radioactive material, n.o.s.,\" with identification number \"UN 2982.\" LSA packaging\nrequirements and communications requirements provide for some relief from the corresponding\nrequirements for \"Radioactive material, n.0.s.\" This relief is based primarily on the inherently\nsafe nature of the quantity and distribution of activity in the LSA material.\nAs in the past, LLW which have the activity incorporated into the waste matrix are the materials\nwhich will most likely satisfy the LSA material definitions. However, any radioactive material\nwhich can be demonstrated to satisfy the LSA definitions and the unshielded dose rate could be\ncategorized as LSA and shipped in accordance with 49 CFR 173.427 (DOT, 1996). To be\ncategorized as such, it must either be nonfissile or fissile excepted (49 CFR 173.427(a)(3).\n\n<<<PAGE 15>>>\n\nLow Specific Activity Material\nNote that any radioactive material which meets the requirements in 49 CFR 173.421, for\nexcepted packages of limited quantities of Class 7 (radioactive) materials, can be shipped as\n\"Radioactive Material, excepted package, limited quantity of material,\" with an identification\nnumber of \"UN2910.\" The.activity per package in a normal fohn exce ted package shipment\nP\n(such as an activated or a contaminated object) would be limited to 10- A, as given by Table 7 of\n49 CFR 173.425 (DOT, 1996). In such cases,there is no need to evaluate for compliance with\nthe LSA definitions.\nIt is expected that much the of waste fiom nuclear power plant operations will be categorized as\nLSA-I1 material. Examples of candidate LSA-I1 materials fiom process waste streams would be\ndewatered ion exchange media (i.e., resins), evaporator bottoms, mechanical filters and filter\nmedia, absorbed liquids, and other similar process waste types. Other examples of LSA-I1 would\nbe demolition rubble which exceeds LSA-I limits, activated metals, organic liquids (e.g.,\nscintillation fluids or oils), removed paint, and biological wastes. Thus, the great majority of\nmaterial that has previously been shipped as LSA material can continue to be shipped as LSA-I1\nmaterial under the revised regulations.\nCompactable and noncompactable trash (e.g., dry active wastes, or \"DAW') is an ambiguous\ncategory, possibly candidate for categorization as either LSA material or SCOs. For example,\nmaterials that absorb or incorporate the radioactivity (e.g., towels, rags, labwipes, clay for\nabsorbing spills, or tape) would be candidate LSA material. Contaminated objects (e.g.,\ndiscarded gloves, tools, hardware, labware and glassware) might more appropriately be\nconsidered as candidate SCOs. However, it is not the intent of the transportation regulations to\nrequire segregation of these materials solely for purposes categorization as LSA material or\nSCOs. If qualitative judgement and experience indicates that there is no reason to believe that\nthe SCO contamination limits on objects would be exceeded (this experience would be gained\nthrough operations knowledge and periodic health physics surveillance), then the objects could\nbe mixed in a single package, along with materials which are clearly categorized LSA material by\ntheir nature (e.g., DAW or even LSA waste materials) and shipped according to the requirements\nof 49 CFR 173.427, as \"Radioactive material, LSA, n.0.s.\" with identification number\n\"UN2912.\" This practice is generally acceptable provided the LSA-I1 definition is otherwise\nsatisfied, and the package contains less than 1 A, quantity (the great majority of DAW packages).\nIn greater quantities, the practice may also be justified on a case-by-case basis. See section 6.1.1\nfor further details.\nThe current regulations do not place limits on contamination for LSA material. Therefore, there\nis no requirement to comply withthe SCO surface contamination limits for LSA material. A\ncontaminated, activated object may be categorized as LSA material insofar as it otherwise meets\nthe requirements of the applicable LSA definition; however, an activated object may not be\ncategorized as an SCO. Any contamination on the surfaces of LSA material must be accounted\nfor in characterizing the material or object as LSA, and in determining the nuclides present in the\npackage in accordance with 49 CFR $9 173.433 and 173.435 (i.e., the \"95% A, sum of fractions\nrule), to be reported on shipping papers and labels (if not excepted from labeling). Also, since\nthe contamination on the surface of LSA material may be from a different waste stream than the\nwaste's (or object's) contained activity, it may not be accounted for in the sample data base used\n\n<<<PAGE 16>>>\n\nLow Specific Activity Material\nto estimate nuclide concentrations. In this event, any such contamination should be identified\nand properly accounted for in categorizing the material for shipment.\nThe proper shipping name in these cases is \"Radioactive material, n.0.s.\" with the identification\nnumber of \"UN2982\" and, with one exception described below, a Type B package is required\ndue to the quantity of material. If a material can otherwise satisfl the LSA requirements, but the\n10 mSv/hr (1 rernthr) at 3 m (9.9 ft) unshielded dose rate limit is exceeded, then the material no\nlonger meets the intent of the LSA material regulations justifling the use of less robust packaging\nthat would otherwise be required for Type B quantities of material. Also, Type B packages are\nnot excepted fiom DOT marking and labeling requirements, as other packages for LSA\nsometimes are [49 CFR 173.427 (DOT, 1996)l.\nNRC regulations [lo CFR 7 1.52 (NRC, 1996a)l allow that previously-certified NRC packages\nfor LSA materials (i.e., NRC Type A-LSA packages) may continue to be used for LSA and SCO\nshipments until April 1, 1999. The \"Directory of Certificates of Compliance for Radioactive\nMaterials Packages,\" NUREG-0383 (NRC, 1996d) provides a compiled list of NRC certified\npackage designs. These package designs can continue to be used as under previous regulations\n(see section 6.3.4), provided the conditions in the certificate of compliance (CoC) are complied\nwith. They can be used for LSA material exceeding the 10 m S v h (1 re*) at 3 m (9.9 A)\nunshielded dose rate limit. The proper shipping name for LSA material shipped using these\npackages is \"Radioactive material, LSA, n.o.s.\" with identification number \"UN2912,\" and the\npackages are exempted from DOT marking and labeling requirements as specified in\n49 CFR 173.427(a)(6)(vi) and (b)(4)'.\nNRC and DOT staff believe that the best approach to the small contaminated object issue is to\nsimplify the process for their categorization as SCOs, rather than to classify them as LSA\nmaterial. Nonradioactive objects whose surfaces are contaminated with radioactivity are clearly\ncandidate SCOs, not LSA material, regardless of size. Accordingly, when possible, the method\ndescribed in Section 3.3.1 should be used to categorize collections of small objects as SCO. The\ncontamination on each small object is not required to be measured. Rather, a representative\nsample of the smdl objects can be assessed, and the activity and surface contamination in the\nentire collection can then be estimated. Unless evidence suggests otherwise, it is generally\nacceptable to assume uniform contamination over the surfaces of collections of these small\nobjects. If successfblly characterized as SCO-I or SCO-11, the objects should be shipped using\nthe proper shipping name, \"Radioactive material, SCO\" with identification number \"UN29 13.\"\nSee also section 6.1 for guidance on the mixing of LSA materials with SCOs.\n'Note: 49 CFR 173.427(b)(4) was issued in the corrections rule (61 FR 20747) to the initial rule (60 FR 50292).\n4-3 NUREG- 1608\n\n<<<PAGE 17>>>\n\n. Low Specific Activity Material\nThere are no restrictions which prohibit categorizing solidified, absorbed, or activated metal\nradioactive material as LSA-11, provided the definition is otherwise satisfied (i.e., specific\nactivity limits, distribution requirement, and dose rate limits are met). Inclusion of the term solid\ncompact binding agent in the LSA-I11 definition was not intended to preclude categorizing these\nmaterials as LSA-11. Similarly, activated metals are suitable for evaluation as possible LSA-I1\nmaterial, even though the tenn is explicitly cited as an example of a possible LSA-111 material in\n10 CFR 7 1.4 and 49 CFR 173.403.\nAlso, materials such as decommissioning wastes which exceed the LSA-I average specific\nactivity limit, can also be evaluated as a possible LSA-I1 material.\nIn order to be considered in the determination of the average specific activity, or in the\ndetermination of unshielded dose rates, the radioactive material must be incorporated into the.\ngrout or binding agents.\nIf grout is used as shielding, structural support, or encapsulating material (i.e, the object or\nradioactive material is not incorporated into the grout), the grout should not be included in the\nLSA determinations. This situation would not meet the applicable LSA material definition's\nactivity distribution requirement.\nThe LSA-I11 leach test is specified in 49 CFR 173.468 and 10 CFR 7 1.77 (DOT, 1996; NRC,\n1996a). Radioactive waste forms that contain less than 1 A, quantity of radioactive material can\nbe presumed to satisfy the LSA-I11 leach test requirements if they have been prepared under a\nprocess control plan (PCP) associated with an approved waste solidification recipe in accordance\nwith NRC's Technical Position (TP) on Waste Form, Rev. 1 (NRC, 1991). However, since the\nTP on waste form only addresses Class B and Class C LLW, only LLW which is stabilized by\nsolidification in order to satisfy the 10 CFR 6 1 (NRC, 1996c), in compliance with the TP, can\nuse this method for satisfying the leach test requirement for LSA-I11 shipments.\nYes, although the LSA-111 leach test [49 CFR 173.468 and 10 CFR 71.77 (DOT, 1996; NRC,\n1996a)l states that, \"the specimen, representing no less than the entire contents of the package,\nmust be immersed for 7 days in water at ambient temperature; ....\", the wording is not intended to\nimply or require that the contents of each packaging being characterized must be leach-tested\nNUREG- 1 608 4-4\n\n<<<PAGE 18>>>\n\nLow Specific Activity Material\nprior to transport. Also, the requirement is not meant to imply that Ill-scale.tests are necessary\nto comply with the regulations. If frequent LSA-111 shipments are expected, use of a process\ncontrol program (PCP), similar to that used for compliance with the TP on waste form (Rev. 1)\n(see section 4.1.7 above), is one acceptable means of demonstrating compliance with the LSA-I11\nleach test. At a minimum, such a program would include periodic sampling (i.e., control\nspecimens), address waste stream consistency, and correlate lab-scale test results to full-scale test\nresu","truncated":true,"body_characters":52788}