Type A Packaging of Fissile Materials
General: Type AF shipments are needed. This white paper examines AF packagings for shipment of Type AF materials within the United States. It does not address the use of certified Type B packagings for domestic shipments or International containers approved for import/export shipments only.
Two Type A packaging options exist for shipping Type A quantities of fissile radioactive materials:
- DOT specification packaging and
- packaging certified by either DOE/EM-33 or by NRC.
DOT packagings include DOT Specification 7A Type A packaging tested to meet the fissile requirement 49 CFR 173.465(c)(2). The mass limits and criticality control (via criticality safety index, CSI) are specified by 10 CFR 71.22.
The other option in Type A packaging for shipping Type A fissile material is a DOE or NRC certified AF design. These certificates must be supported by a SARP. The design must meet the general requirements of 10 CFR 71.41 through 71.47, the requirements of 10 CFR 71.71 (Normal Conditions of Transport), and the package must remain sub-critical under the requirements of 10 CFR 71.73 (Hypothetical Accident Conditions).
Regulations: The following regulatory guidance applies to Type A fissile packaging requirements.
49 CFR 172.101: UN3327, Radioactive Material Type A package, fissile, non-special form, and UN3333, Radioactive Material Type A packages, special form, fissile. Both forms reference 49 CFR 173.417 for packaging requirements.
49 CFR 173.7(d): DOE authority to issue DOE certificates for use by DOE contractors comes from this section of the regulations, and requires the DOE certification process to be equivalent to 10 CFR Part 71.
49 CFR 173.401 Scope: "The requirements prescribed in this subpart are in addition to, not in place of, other requirements set forth in this subchapter for Class 7 (radioactive) materials and those of the Nuclear Regulatory Commission in 10 CFR Part 71." Type B and fissile material packaging standards are the purview of the NRC, and DOT simply references their requirements in 49 CFR.
49 CFR 173.417 basically allows the use of packagings listed in 49 CFR 173.415 in addition to certified Type AF, Type B(U)F, and Type B(M)F packagings.
49 CFR 173.415(a) authorizes the use of DOT 7A Type A packagings;(b), the use of certified Type A packagings for fissile material; (c), the use of certified Type B(U) or B(M) packagings; and (d), the use of internationally certified containers.
49 CFR 173.465 gives requirements for Type A performance testing.
49 CFR 173.465(c)(2) specifies additional performance tests for fissile Type A performance.
49 CFR 173.467, Tests for demonstrating the ability of Type B and fissile material packagings to withstand accident conditions in transportation: "Each Type B packaging or packaging for fissile material must meet the test requirements prescribed in 10 CFR Part 71 for ability to withstand accident conditions in transportation." This implies that AF certified packagings must meet 10 CFR 71.73, Hypothetical Accident Conditions.
10 CFR 71.22, General License: Fissile Material: Authorizes the use of DOT Specification 7A, puts restrictions of the contents, and assigns values for CSIs.
10 CFR 71.55(a): The first sentence states all fissile packagings must be designed and constructed in accordance with 10 CFR 71.41 through 71.47.
10 CFR 71.55(a): The second sentence in this section states: "When required by the total amount of radioactive material, a package used for the shipment of fissile material must also be designed and constructed in accordance with 10 CFR 71.51, Additional requirements for Type B packages." This implies that the total amount of radioactive material to be a Type B quantity.
10 CFR 71.55(d): A package used for shipment of fissile material to be so designed and constructed and its contents so limited that under the tests specified in 10 CFR 71.71 (Normal Conditions of Transport) the conditions listed under 71.55(d) are met.
10 CFR 71.55(e): A package used for the shipment of fissile material must be so designed and constructed and it contents so limited that under the tests specified in 10 CFR 71.73 (Hypothetical Accident Conditions), the package would be sub-critical and the conditions listed under 71.55(e) are met.
Regulatory Guide 7.9, Standard Format and Content of Part 71 Applications for Approval of Packages for Radioactive Materials: The first sentence states: "This regulatory guide provides guidance on preparing applications for approval of Type B and fissile material transportation packages." Therefore, this guide should be implemented in applications for a Type AF certification.
Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging used in Transport of Radioactive Material: The first sentence states: "This regulatory guide provides guidance for use in developing quality assurance (QA) programs for packaging to be used in shipping Type B and fissile radioactive materials." Therefore, this guide should be implemented in applications for a Type AF certification.
Use of a DOT Special Permit (SP) for relief from 10 CFR 71.22: In the past, DOE has requested a Special Permit from the DOT for relief from the restriction on DOT 7A Type A packaging for fissile material. As part of the request, DOE submitted justification to allow contents based on criticality analysis instead of the Criticality Safety Index stated in 10 CFR 71.22. In response, DOT asked DOE to cancel its request for a DOT SP and either to issue a DOE Type AF certificate or seek an NRC Type AF certificate for the requested shipments.
Request for NRC Type AF Certificate: DOE recently submitted a request for a Type AF certificate from the NRC. The NRC certificate was needed for this unique case, because some of the shipments would be made by NRC license holders and not by DOE contractors. A nine chapter Safety Analysis Report (SAR) was required by the NRC to conduct the review. The ninth chapter described how Quality Assurance was implemented by DOE when DOE contractors made shipments under the NRC certificate.
Created June 20, 2014