DOE Guidance for Applications to
DOT for IAEA Special Form RAM Certificates, 49 CFR 173.476

This guidance applies only to DOE and DOE Contractors

Based on feedback from DOT, DOE applications to DOT for IAEA Special Form Radioactive Materials Certificates have on occasion contained unnecessary information and/or lacked certain required information, both of which complicate and delay the review.  Consequently DOE applications require a much lengthier review cycle by DOT than is necessary.  Therefore, to improve the quality of DOE applications and reduce the DOT review cycle, the DOE Packaging Certification is issuing the following guidance to DOE/DOE Contractors regarding Special Form applications for DOT:

  • Most successful applications are typically on the order of about 10 to 20 pages in length.

  • The application must address the requirements in 49 CFR 173.403 (definition of Special form Class 7 (radioactive) material), 173.469, and 173.476(c).

  • Send the following documents to the DOE Packaging Certification Program

    • Request letter to DOE PCP from the Site/Field Office, with the Application.

    • Application should consist of the following:

      1. Test Report: needs to be concise with no extraneous information (see outline below)

        1. Introduction - briefly describe the use of of the source, radioactive contents, and regulatory requirements (e.g., ... source material/capsule has been designed to satisfy the criteria for special form radioactive materials as prescribed in 49 CFR 173.403, and 173.469, 10 CFR 71.75, and IAEA TS-R-1, 1996 Edition, or 2009 Edition, or successor IAEA special form standards/regulations incorporated by reference in the HMR.)

        2. Source Description - be sure to include a brief narrative description, including materials of fabrication, construction, and metric system overall outer dimensions and thicknesses for use on the certificate.  Reference the drawings and QA requirements.

        3. Radioactive Contents - be sure to include a brief description of the radioactive materials, including isotope(s), quantity, and physical/chemical form for use on the certificate (see an approved Certificate for example).  SI units are required.

        4. Test Assessment - describe the test specimens, tests performed, and acceptance criteria.  Summarize the test results (passed), and conclusion (source material/capsule meets the test conditions for special form radioactive materials).  Reference test data documentation.

        5. Quality Assurance/Quality Control - Reference the QA Program requirements for the source material/capsule (e,g, manufacturing of the source material/capsules is performed in accordance with an approved QAP (e.g., 10 CFR Part 71 Subpart H, ISO 9001).  Cite the weld and dimensional inspection requirements, and leakage test requirements.

        6. Test Data Documentation (e.g., test results, data sheet, certificate) - actual results that confirm the test assessment, NOT blank data sheets, test plans, and procedures
      2. Drawing - detailed construction drawings may be provided.  In addition, a descriptive drawing of an assembled capsule is needed to attach to the certificate that contains a legend with name, drawing no., rev., units of measure, etc.  The units of measure should be metric, cm or mm; parenthetical inches can be used.  (see an approved Certificate for example)
To avoid common mistakes in requests from all applicants make sure to:

  1. Use the correct ISO/ANSI Standard revision allowed by the regulations (Ref §173.469 and §171.7).  The most recent revision is not necessarily approved for use.

  2. Provide an appropriate void volume when using alternative leak testing (Ref §173.469(a)(4)(i) or ISO 9978).

  3. Provide the capsule mass when using alternative physical testing (Ref §173.469(d)).

  4. Specify the specimen did not break or shatter when subjected to the impact, percussion, or bending tests; and did not melt or disperse when subjected to the heat test.

  5. Conduct a leaktightness test after each physical test.

  6. Use a volumetric test if using a leakage assessment test in ISO 9978.
Information previously provided to DOT and which they have on file should not be resubmitted, especially in the case of a certificate application to only extend the expiration date.

If needed, DOT personnel are available to discuss any questions or concerns regarding an application.  Contact the DOE Docket Manager to schedule a call with DOT regarding the application.

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Washington DC 20585

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