DOE Guidance for Preparing Applications to
DOT for IAEA Special Form RAM Certificates

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This guidance applies only to DOE elements or persons working under contract to DOE elements

DOE elements means programs, operations offices, field/site offices, and other organizational units of the Department of Energy, excluding those of the National Nuclear Security Administration.  The list of DOE elements is here.  (link to DOE Directives website).

This guidance webpage will refer to DOE elements or persons working under to contract (i.e., contractors) to DOE elements as the "Applicant to DOE", unless otherwise specified.  For DOE application submittals to DOT, the DOE Packaging Certification Program (PCP) Manager or DOE Headquarters Certifying Official (HCO) is the "Applicant to DOT."

Requirements
DOE Order 460.1D, Hazardous Materials Packaging and Transportation Safety  (opens pdf) requires Applicants to DOE to file a request to the HCO for a new International Atomic Energy Agency (IAEA) Certificate of Competent Authority (CoCA) for Special Form Radioactive Materials (RAM), or a request for revision to a CoCA (e.g., to revise the source description/design, radioactive contents, or to extend the expiration date).  The U.S. Competent Authority is the Department of Transportation (DOT).

DOE Guidance to prepare a sufficient application for a CoCA
Based on feedback from DOT, DOE applications to DOT for IAEA Special Form RAM 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 PCP is issuing the following guidance to Applicants to DOE for CoCA actions.   

• Most successful applications are typically on the order of about 10 to 20 pages in length, or less.
• The application must address the requirements in 49 CFR §§173.403, 173.469, and 173.476(c)  (link to DOT regulations).
• The Applicant to DOE must submit the following documents to the HCO:
  
  • A memorandum or letter from the DOE Element (Operations Office or Site/Field Office Manager) to the HCO requesting a new CoCA or a revision to an existing CoCA.  If the revision is only to extend the expiration date, then follow the instructions on the RAMPAC certificate renewal page.
  • An application for a new CoCA should consist of the following items.  An application for revision to an existing CoCA should only consist of the changes to the following items:
    
    
    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 Identification - how you want to refer to the source, by name.  It should be consistent with the drawing name/title.
       3. Source Description - be sure to include a brief narrative description, including materials of fabrication, construction, welding method, and overall outer dimensions and thicknesses (in metric) for use on the certificate.  Reference the drawings and QA requirements.
       4. Radioactive Contents - be sure to include a brief description of the radioactive materials, including all isotope(s), quantity, and physical/chemical form for use on the certificate (see an approved Certificate for example).  SI units are required.
       5. Test Assessment - describe the test specimens, specific 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.
       6. 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.
       7. Test Data Documentation (e.g., test results, data sheet, certificate) - actual results that confirm the test assessment.  Do NOT include blank data sheets, test plans, and procedures.
    2. Drawing - detailed construction drawings may be provided or available to DOT upon request.  In addition, a descriptive drawing of an assembled capsule is needed to attach to the certificate that contains a legend with name/title, 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 CoCA for example: CoCAs are identified on the RAMPAC DOT-IAEA certificate page by the "/S" in certificate Package Identification Number, e.g., USA/0018/S-96)

To avoid common mistakes/omissions in applications for a CoCA , the Applicant to DOE should:

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.

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

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Questions or comments? Contact the DOE PCP Docket Manager, Lawrence F. Gelder [CONTR], (803) 645-3490, lawrence.gelder@em.doe.gov

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Updated May 2, 2017 and July 9, 2024