Guidance for Type B or Fissile Package Certificate Content Questions


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 posted hereexternal (link to DOE Directives website).

Only DOE elements or persons working under contract to DOE elements (i.e., contractors) shall consign a DOE certified package for shipment.  NRC licensees or Agreement State licensees shall not consign a DOE certified package for shipment, but can transfer the material on-site to DOE elements or persons working under contract to DOE elements, for consignment of the package.  ​See NRC legal interpretation: Transfer by an NRC Licensee of Radioactive Material or of Radioactive-Contaminated Facility Components to the Department of Energy External Link(External link to NRC website)

The following guidance is intended to provide a process for DOE elements or contractors to request and receive clarification regarding questions about authorized contents for packages certified by DOE, and guidance for DOE Certificate Holder evaluations of user content clarification requests.     

Clarification Regarding Authorized Contents for Type B ​or Fissile Package Designs ​certified by​ DOE
Periodically, DOE registered users need clarification to ensure their contents are compliant with the authorized contents listed in a Certificate of Compliance (CoC) for a Type B or fissile package design.  The following steps are recommended by the DOE Packaging Certification Program (PCP) to obtain clarification:    

  1. Describe your proposed contents with respect to the CoC and note any and all deviations. Refer to §71.33 (b) and NRC Regulatory Guide 7.9, Section 1.2.2, for a complete and thorough content description and note any and all deviations from the authorized content definition(s) in the CoC. 
  2. Contact the certificate holder point of contact (https://rampac.energy.gov/home/package-certification-information/points-of-contact#DOE) to evaluate your proposed contents, and to document their evaluation in writing.
  3. If your contents are not compliant with the authorized content definition(s) in the CoC, work through the certificate holder to submit a request to DOE PCP to amend the CoC or find another candidate package.
  4. If your contents are compliant with the authorized content definition(s) in the CoC per the certificates holder’s evaluation, provide a copy of the evaluation to the DOE PCP Manager and maintain a copy with your package operations records.

Content Evaluations by the Certificate Holder
Each certificate is issued by DOE on the basis of a safety analysis report of the package design (SARP), as supplemented.  If a calculation is required in addition to the applicable SARP calculations to demonstrate that the proposed contents are compliant with the CoC, then the certificate holder ​must submit the calculation to DOE PCP for independent confirmatory review.  DOE PCP will review the calculation and will determine, in writing to the certificate holder, if a CoC amendment is required or issue a letter or memorandum of concurrence.  


 
​Questions or comments? Contact the DOE Packaging Certification Program Manager, Dr. Shuler, (301) 903-5513, james.shuler@em.doe.gov

Added ​​​October 1, 2019



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