DSHW-2025-001229

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APPENDIX A
(Preparation For Transport)
The transport of devices containing radioactive sources is regulated by the rules and
requirements of the US Department of Transportation. These rules require that the
device be transported in a DOT approved Type A container, sometimes the device itself
will meet the Type A requirement.
A particular problem arises when you are required to transport a defective device
containing a source where the device shutter is stuck in the “OPEN” position. Such
devices are to be transported in an approved Type A container. A further problem arises
when additional shielding is required to be attached to the defective device to avoid
exceeding surface dose rate limits of the final Type A package.
The following procedure addresses the required minimum steps to prepare a defective
device for transport.

__ Ascertain the Isotope and activity along with any known dose rate information.
The most likely Isotopes will be Co60, Cs137, Am241, Am241-Be, or Cm244.
__ Determine the thickness and type of material to be added to the face of the device.
(Lead or steel for Gamma sources and Boron with polyethylene for Neutron sources).
__ Determine the best method of securing the extra shielding to the device to ensure
that the shielding material does not move or become separated from the device during
transport. If (as is common to many designs) the device is mounted by bolts around the
exit beam path, determine the bolt pattern dimensions so that the additional materia l
can be drilled and attached to the defective shielding using the same diameter of bolt as
those used to initially mount the device. Alternatively, if it is not possible to use bolts,
plan on attaching the extra material to the damaged shielding using web strapping rated
for 1000lbs dead weight. Supplement with additional metal straps if necessary.
__ Select a suitable Type A container and plan how the device is to be prevented from
moving inside the container during transit using wood bracing or other suitable overfill
material.

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__ Once the device has been shielded, place the device into the Type A container and
add bracing or overfill material as needed.
__ Close the final package following the closure instructions specific to the tType A
container being used (e.g., Skolnik Drum, CPC B-12, etc.).
__ Once closed, complete final package surveys to ensure that the package is in
compliance with DOT rules and requirements and label the container accordingly.

1
GL Training Procedure

Purpose

The State of Tennessee allows Berthold technologies USA, LLC to distribute products to General
Licensees under TN Regulation 0400-20-10.10 and its USNRC equivalent CFR 10 Part 32. This implies
that the general Licensee is operating under a license issued under USNRC rules and regulations CFR 10
Part 31.5 or Agreement State equivalent (TN 0400-20-10.10(2)). This allows the user the restricted
rights to acquire, receive, possess and mount devices containing sealed sources, provided that the
devices are manufactured and labeled in accordance with the specifications contained in the device
registrations. ONLY persons specifically licensed by the USNRC, or an Agreement State may install or
commission devices. The customer must be absolutely clear what his/her duties are and who to contact
in case of questions or problems. The elements of the training are described in this procedure.

Pre-Shipment

Prior to the shipment of a device to a customer, the RSO shall contact the customer and provide them
with a Licensing Packet/Manual that includes the following;

1. License Selection Form (Attachment A)
2. Licensing Guide for General and Specific License Categories (Attachment B)
3. TN SPAR 0400-20-10-.10 (Attachment C)
4. Regulatory Contact Info (Attachment D)
5. Source & Shield Guidelines for Receipt & Mounting (Attachment E)

Shipment

Every device distributed by Berthold Technologies USA, LLC shall be clearly labeled to indicate:

1. Instructions and precautions to assure the safe installation, operation, and servicing of the device
or reference to where this information is located.
2. The requirements (or lack of requirements) for leak tests and shutter tests.
3. The following statement: “The receipt, possession, use and transfer of this device is subject to a
general license or the equivalent and the regulations of the U.S. Nuclear Regulatory Commission
or of a State with which the NRC has entered into an agreement for the exercise of regulatory
authority. This label shall be maintained on the device in a legible condition. Removal of this
label is prohibited Licensed in the State of Tennessee.”