PRECEDENTS FOR AUTHORIZATION OF CONTENTS USING DOSE RATE MEASUREMENTS Page: 3 of 11
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SRNL-STI-2012-00317
12-A-426-INMM
The regulations are based on the acceptable dose rates to which the public, workers, and the
environment may be exposed and mirror those found in 49 CFR 173.441. As such, the
regulations specify dose rates, rather than quantity of radioactive isotopes and require monitoring
to confirm the requirements are met. Before shipment, the dose rate of the package is
determined by measurement, ensuring that it conforms to the regulatory limits, regardless of any
analyses. This is the requirement for all certified packagings. However, there have occurred
instances where either the definition of a bounding content was not possible, where definition of
impurities within the RAM was not possible, where the physical form of the content made
modeling and analysis not practical, or where the mixing of the RAM and impurities were not
know and bounding calculations yielded dose rates that were unrealistic high and exceeded the
10 CFR 71 limits. In these cases, regulatory compliance of a package at the time of shipment
has been established through dose rate measurements. This paper discusses the requirements for
establishing the dose rates when shipping RAM packages and the precedents for meeting these
requirements by measurement.
Discussion
Within the U.S. Department of Energy (DOE), DOE Order 460.1C [Ref. 2] defines the actions
required of each entity prior to shipment of RAM. DOE Order 460.1C(2)(d) requires: "For a
new DOE or NNSA Type B or fissile material packaging each entity must submit an application
to the Certifying Official that includes a Safety Analysis Report for Packaging (SARP) and any
other supporting documentation to demonstrate that the packaging meets the requirements of
10 CFR Part 71." Each certifying organization, the International Atomic Energy
Agency (IAEA), the Nuclear Regulatory Commission (NRC), and the DOE, has guides and
standards for assistance in the preparation of SARPs defining the minimum essential elements
required to establish the safety basis for the RAM packaging. With respect to compliance with
the dose rate limits the following are provided, with the pertinent passages italicized. It is noted
that these requirements and guidance address the shielding calculations necessary to establish the
package safety basis but also discuss confirmatory or compensatory measurements.
IAEA Safety Standards TS-R-1 [Ref. 31:
Radiation Protection
301. Doses to persons shall be below the relevant dose limits. Protection and safety shall be
optimized in order that the magnitude of individual doses, the number of persons exposed,
and the likelihood of incurring exposure shall be kept as low as reasonably achievable,
economic and social factors being taken into account, within the restriction that the doses to
individuals be subject to dose constraints. A structured and systematic approach shall be
adopted and shall include consideration of the interfaces between transport and other
activities.
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Abramczyk, G.; Bellamy, S.; Nathan, S. & Loftin, B. PRECEDENTS FOR AUTHORIZATION OF CONTENTS USING DOSE RATE MEASUREMENTS, article, June 5, 2012; United States. (https://digital.library.unt.edu/ark:/67531/metadc830621/m1/3/: accessed April 24, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.