Guidance for Reporting Packaging Damage and Defects
(effective date 11/13/2017 )


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).

Periodically, the Department of Energy (DOE) Packaging Certification Program (PCP) receives questions by DOE package users related to damaged components of certified Type B and Fissile radioactive material packagings, that can be summarized as follows:

"What should a user do if they are not sure if damage or a defect to a Type B or fissile packaging component is only superficial, as defined in 10 CFR 71.87(b)?"

PCP discussed this question with Nuclear Regulatory Commission (NRC) colleagues and they concur with the following assessment:

Note - In the ensuing discussion, the requirements for "licensees" apply to the DOE registered users of DOE and NRC certified packagings.

After first use of packaging, one should reasonably expect some superficial defects to the packaging over time from normal use: §71.87(b) addresses these type of defects, "Before each shipment ... The licensee shall determine that-... (b) The package is in unimpaired physical condition except for superficial defects such as marks or dents; ..." One could infer that damage to packaging from the Normal Conditions of Transport tests and conditions would typically be considered "superficial."

But, if a licensee (DOE registered user) is not sure a packaging component defect or damage is superficial, they should notify the certificate holder to evaluate and disposition the component in accordance with their Quality Assurance Plan's implementation of §71.131, Nonconforming materials, parts, or components, and include this information in their §71.91, Records, system for the packaging serial number.

If the certificate holder's disposition is to use the component as-is (accepted) because the defect does not affect the safety feature(s) of the component and does not result in a significant reduction in the effectiveness of the packaging, then the issue is closed. However, if the component is rejected, or needs repaired or reworked, then the licensee (DOE registered user) will need to notify the DOE Certifying Official if the component is from a DOE certified packaging or notify NRC if the component is from NRC certified packaging, per 71.95(a)(1) and/or (2).


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

Added ​November 13, 2017



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