Certification of DOT 7A Type A Packaging in Type AF Configurations

Based on the U.S. Department of Transportation (DOT) regulations in 49 CFR 173.7(d), the U.S. Department of Energy (DOE) Order 460.1B (DOE 2003) codifies the authority of certification of Type-B and fissile material transportation packaging to the Office of Environmental Management (EM), except for materials of interest to national security, naval propulsion systems, and civilian radioactive waste management. DOE Order 460.1B also stipulates that the EM certification of Type B and fissile materials transportation packaging shall be in accordance with the U.S. Nuclear Regulatory Commission (NRC) safety standards in 10 CFR Part 71. The Packaging Certification Program (PCP) of the Office of Safety Management and Operations (EM-60) is supported by technical review teams at Argonne National Laboratory and Lawrence Livermore National Laboratory. In recent years EM-60 has received requests for certification of fissile material packages for the shipment of low-enrichment uranium oxides in DOT 7A Type A drums in Type AF configurations. One request originally sought for DOT exemption (i.e., special permit) per 49 CFR 107, Subpart B that underwent reviews by DOE, NRC, and DOT. DOT eventually advised DOE that the packaging should be certified as a DOT 7A Type A drums in a Type AF configuration. Historically EM-60 has also issued Certificate of Compliances (CoC) for low-enrichment fissile uranium metals in wooden boxes as Type B packages for shipment, even though the wooden boxes do not meet the structural and thermal requirements in 10 CFR 71 under hypothetical accident conditions. There are also provisions in 10 CFR 71.15 for exemption from classification as fissile material, and in 10 CFR 71.22 General license: Fissile material that specifically references the DOT requirements in 49 CFR 173.417(a) for Type A package. The myriad of NRC and DOT regulations applicable to fissile materials and Type A packages availed alternative approaches in the requests for packaging certification; however, in all cases the primary concern for fissile material packages is the assurance of criticality safety in the shipment under both normal conditions of transport and hypothetical accidents. This paper will present a case in the certification of DOT 7A Type A packaging in Type AF configurations, drawing highlights from a recent certification review of packagings for shipment of low-enrichment uranium oxides in Type A drums. Various regulatory requirements are also discussed.