Regulatory Guide 5.10
| ML003740020 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1973 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| References | |
| RG-5.10 | |
| Download: ML003740020 (3) | |
x July 1973 U.S. ATOMIC ENERGY COMMISSION
REGULATORY
DIRECTORATE OF REGULATORY STANDARDS
GUI DE
REGULATORY GUIDE 5.10
SELECTION AND USE OF PRESSURE-SENSITIVE SEALS ON CONTAINERS
FOR ONSITE STORAGE OF SPECIAL NUCLEAR MATERIAL
A. INTRODUCTION
1. Composition. The seal is basically a backing on one surface of which is a layer of adhesive covered by a Paragraph 70.22(b) of 10 CFR Part 70, "Special protective liner.
Nuclear Materials," requires that certain applicants for licenses to possess special nuclear material (SNM) The backing of pressure-sensitive labels or seals is provide a full description of their procedures for control usually made of paper, vinyl film, or plastic-coated paper of and accounting for the SNM possessed under license, and may be composed of more than one layer. To induding procedures used in storing said material. provide a consistent degree of adhesion, the adhesive on Paragraph 70.32(c) requires that licenses authoriking the backing should be aggressively tacky at room possession of certain quantities of SNM contain and be temperature and not require activation by water, subject to a condition requiring the licensee to maintain solvents, or heat to form a bond to the container to fundamental material controls identified in Part 70 and which it is to be applied. Curing adhesives which harden other material control procedures deemed essential by as a result of exposure to air are not recommended the Commission for the safeguarding of SNM. Section because the initial adhesion should be adequate, and
70.56 requires licensees to perform, or permit the further adhesion only increases the difficulty of cleaning Commission to perform, tests appropriate or necessary old seals from reusable containers.
for the administration of the regulations in 10 CFR Part
70, including tests of equipment and devices used in The surface of the seal should carry a logotype to connection with the production, utilization, or storage identify the licensee, and the complete surface of the of SNM. seal should be covered with a regular and fine design to reveal erasures.
Pressure-sensitive seals on containers used for onuite storage of SNM are passive devices that indicate, upon All seals should provide enough space to write by inspection, whether tampering or entry has occurred. hand the type of material; the composition, weight, and These seals may also serve as labels. This guide provides serial number of items; the initials or signature of the criteria acceptable to the Regulatory staff for selecting, person responsible for the statement of content. and the affixing, and testing pressure-sensitive seals used for date of application of the seal.
tamper-safing in connection with the onsite storage of SNM for compliance with the Commission's regulations Lettering on the seal, other than the logotype, with respect to material control. should be large enough to be easily readable. The writing materials used to record information on the seals should
B. DISCUSSION
be specified on the basis of qualification tests that establish compatibility with the surface of each type of The effective use of pressure-sensitive seals for seal.
tamper-safing containers of SNM in onsite storage should consider such basic elements as (1) composition, (2) seal
2. Seal Properties. From the point of view of tamper properties, (3) method of affixing, (4) seal control, and resistance, the backing, adhesive, and ink of the seal
(5) quality assurance. should resist without damage all chemicals normally WBAEC REGULATORY GUIOES Capin il ublished ouids ny be obtained by reques idlmlins tw division u - - do 6w US. Atomic EnrgWy Commission. WVahlnor. D.C. 205a, metuimody GudEs 6 i tosc d ator ttetssW met ielleblgto tei public Attesntion: Dietw of Reguaory Stended. Conm1*ta d ksqu smo for nmtlhode ace88pI4e to tthe AIEC Ro atorystaff of4k~lý_eiwtq speaJffk parts of i 0vlms in Ownt gulde we encouragld and should be wt to the Secreta the Commission's resubtione. to delln eatetechniqlues wsedby the eedf In of the commission. U.S. Atomic Energy Commieslon Weeimmigon. D.C. 20545, eelUetNg el c rbei or =oe MWe aocidents, or to provid guldeo to Attention: ChWef.ublicPvoceedin Staff.
applicants. Regulat Guides we not subetitutas for rgoube*to aind
&W ollnce with d1em I not nmrwWkK Methods and olutions diffeent from e t out hi The guNld e issume In the following ton broed dIvons:
do gidee will be
- cceptable If they priLde a besehfor the findingls requisit to the issutn or comnuenm of e permit or limen by timeCommrisIon. 1. POwer Reactors SProucts
2. esserc endTes ReTon11 7. Trmuportatlon Pubisehed sidie will be r perilodicaly, s a oprit 3. Fulserad MItIrle-I Fciliti &. c0cupt0onl leolti to c 4. Enwronmental ard S*ing 9. Antitrust Review comments and to reflect now Information or et'perlence. S. I4esrials ard Plant Protection 1
0. Gera
present in the environment where the seal is to be used. duplication of numbers in use at the facility. Only For example, paper-base seals in general are sensitive to designated custodians or their alternates should have weather exposure; consequently, seals for exterior use access to the seals or affix them to containers. The properties of the inks to be used for printing and should be made with a plastic base.
recording have in common a sensitivity to the solvents Any chemical capable of destroying or softening the that attack the adhesive. Thus seal numbers printed with adhesive should also destroy either the backing or the such inks could be lost if accidentally damaged by solvents. To prevent this loss of identification of the ink of the printing. This is particularly true of paper container, the numbers should be printed with seals with acrylic adhesives that are most likely to tear solvent-resistant inks or as perforations through the when mechanical removal is attempted but are very backing.
permeable to solvents that attack the adhesive. Since the paper backing is usuanly not affected by the solvent, the S. Quality Assurance. The licensee is responsible for ink used in the printing must be sensitive to such demonstrating that the seals have and maintain the solvents in order to provide indication of tampering. required resistance to and indication of tampering. Such a demonstration should include:
In general, paper backing on seals provides a surface a. A solvent test in which an affixed seal sample is capable of accepting various inks well because of the ease of wetting of the paper. Conversely. plastic tested with a solvent to determine the effect on the backings, which are useful in applications requiring adhesive, backing, and inks.
b. A peel test in which a tensile tester is used to exposure to weather, tend to repel inks and have poor penetration, thus requiring special inks with surface determine the acceptability of the tear strength.
active agents that ensure proper wetting of most plastics. c. An erasing test in which rubber erasers and solvents are used to determine if any writing or printing The seal backing should have a tear strength can be erased without a clear indication of erasure.
sufficiently low to provide an indication of tampering by careful peeling of the seal. The tear strength of the
C. REGULATORY POSITION
backing can be reduced and the peel force of the adhesive increased to the point where the peel test is An acceptable program using pressure-sensitive seals satisfied. Another method of preventing peeling without to assist in assuring that the diversion or theft of SNM
tearing is to provide cross-shaped cuts in the backing. from containers in temporary onsite storage has not occurred and also to assist in assuring the validity of Seals should be capable of withstanding normal or previously made measurements should give particular reasonably abnormal wear in use, without damage that consideration to the composition, seal properties, would render the writing illegible or impair the detection method of affixing, seal control, and quality assurance.
of tampering.
I. Compositio
n. The composition of a
3. Method of Affixing. It is important to affix seals pressure-sensitive seal should include:
properly in order to assure that SNM cannot be removed a. A backing or body usually made of paper, vinyl from a container without destroying either the seal or film, or plastic-coated paper;
the container. Surfaces to which seals are to be applied b. An adhesive that covers one of the surfaces of should be clean and smooth. It is recommended that, for the backing and is aggressively tacky at room sealing cans, the seals be designed so they can be applied temperature;
completely across the lid, extending at each end beyond c. A liner that protects the adhesive and that is the lid onto the body of the container for more than an removed prior to affixing;
inch. One such seal might consist of a T-shaped backing; d. Logotype printing on the surface of the seal the cross of the tee is the label with boxes for the identifying the licensee;
handwritten information, and the upright of the tee is a e. A background printing of a fine design covering tape long enough to extend completely across the lid. the complete surface of the seal;
f. Readable lettering.
4. Seal Control. Without adequate control of seals, replacement and subsequent duplication of the affixed 2. Seal Properties. The properties of the seal seal would be more readily possible. There are two components should be selected so that any attempt to simple methods of preventing this type of replacement: tamper with the seal will be clearly indicated. The strict control of the seal blanks and sequential following requirements should be included:
numbering of the seals. As strict control of the seal a. The components of the seal should resist blanks is difficult to maintain and verify, sequential without damage all chemicals in the normal environment numbering is preferred. However, for sequential where the seal is to be used.
numbering of seals to be effective, the seal numbers b. Either the backing material or printing inks I-
should be included in the record system, and the length should yield to chemicals that are capable of of the number sequence should be adequate to prevent compromising the adhesive.
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c. The tensile strength of the seal should be a. Solvent Test. Samples should be prepared by sufficiently low that any tampering by peeling will be affixing at least one square inch of seal material to a indicated by tearing or delamination before the joint clean test panel of the proper material and rolling the between the lid and the container is reached. sample with a 4-112-lb rubber-covered roller (ASTM
Standard D2860-70, "Adhesion of Pressure-Sensitive
3. Method of Affixing. The method of affixing seals Tape to Fiberboard at 90-Deg Angle and should include the following requirements: Constant Stress"'). Markings should be made on the a. The surfaces to which seals are to be applied seal materials with acceptable marking materials. At least should be clean and smooth. five samples of seal material chosen at random from b. A single continous seal, properly shaped, should normally available stock should be tested with each be applied across opposite parts of the joint between the solvent in the solvent test. The test panel and the lid and the container, and the backing and adhesive samples adhering thereto should be immersed in the should extend at least one inch on each side of the joint reagents identified and described in ASTM Standard over a width of at least one-half inch. The seal should be D543-67, "Resistance of Plastics to Chemical Rea affixed with sufficient tension to preclude the tilting of gents,"' 2 within 5 minutes of application and remain the lid allowing access to the contents without damage at room temperature for one-half hour.
to the seal.
c. The seals should be applied immediately after the If for any one sample, the seal material can be samples and data to identify and measure the contents slid off the test panel, or if it falls free during or at the have been taken. end of the period of immersion in any solvent, and if the backing and printing on a sample so removed remain
4. Seal Control. In order to detect replacement or unchanged, the sample and stock should be considered duplication of applied seals, strict control should be to have failed the test.
maintained over the seals in stock. Seal control should include the following requirements: b. Peel Test. At least five samples of the seal a. Seals should be available to and affixed and material should be prepared and mounted on a test panel removed by only designated individuals responsible to in the same manner as in Pressure Sensitive Tape Council material control and accounting management. Standard PSTC-5, "Quick Stick," 3 except that the seal b. Seals should be sequentially numbered with material in this test should be rolled with a 4-1/2-1b sufficient alphameric or numeric digits to prevent rubber-covered roller, as identified in C.5.a above, after duplication of numbers in use at that facility. application. The test panel should be mounted in a jig c. Sequential numbers on seals should be printed which is mounted on a tensile tester as per PSTC-5 and with solvent-resistant inks or as perforations through the the tester started immediately at 0.2 inch per minute.
backing. This peel test should be conducted at a temperature of d. Precise records of all the seals by number should 23 +/- 2 degrees Centigrade. If for any sample, as much as be kept and should include pertinent data on the seal one-half inch of seal material can be peeled free without and data on the contents of the container. Such records tearing or delamination, the sample and stock should be should include any discrepancy that is observed in the considered to have failed the test.
container content, dates and times of application and c. Erasing Test. Where the seal number is not removal of the seal, and the signatures of the individuals perforated in the backing, at least five samples of the responsible to material control and accounting seal material containing the printed seal number should management for the data and for affixing and removing be affixed to a test panel. Rubber erasers and swabs the seal. moistened with all of the standard reagents as indicated e. Assurance should be required of the manufacturer in the solvent test should be used in attempts to erase that their masters of prenumbered seals and the scrap the seal number. Each attempt should be limited to five from fabrication are controlled. minutes duration. If in any attempt, the printing can be erased without leaving a clearly apparent indication of S. Quality Assurance. The licensee should establish a erasure, the sample and stock should be considered to quality assurance program to ensure that the seals have failed the test.
conform to the above requirements. The quality assurance program should include qualification tests of I Copies may be obtained from American Society for seals at each time a new supply of seals is obtained and Tinting and Materials, 1916 Race Street, Philadelphia, Pennsylvania 19103.
with existing stocks at intervals no greater than one year.
The qualification tests should include a solvent test, a 1T11e specific standard reagents for the solvent test are in peeling test, and an erasing test. Tests requiring metallic paragraphs 4.4.3, 4.4.7, 4.4.8, 4.4.12, 4.4.13, 4.4.15, 4.4.16, surfaces should use stainless steel test panels; those 4.4.19, 4.4.21, 4.4.28, 4.4.29, 4.4.31, 4.4.42, 4.4.45, 4.4.48, requiring nonmetallic surfaces should use test panels of and 4.4.50 of ASTM Standard D543-67.
the same material as the container on which the seal is to IC6pies may be obtained from Pressure Sensitive Tape be used. Acceptable test methods are described below: Council, 1201 Waukegan Road, Glenview, Illinois 60025.
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