ABSTRACT Implementation of packaging and transportation requirements can be subdivided into three categories; contents compliance, packaging closure, and transportation or logistical compliance. This paper addresses the area of contents compliance within the context of regulations, DOE Orders, and appropriate standards. Common practices and current pitfalls are also discussed

A C Smith

R W Watkins

S J Hensel

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TYPE B PACKAGE RADIOACTIVE MATERIAL CONTENTS COMPLIANCE 
 
 
 
S. J. Hensel 
Savannah River National Laboratory 
Washington Savannah River Co. 
Aiken, South Carolina 29808 
(803) 208-2783, steve.hensel@srnl.doe.gov 
 
R. W. Watkins 
Washington Savannah River Co. 
Aiken, South Carolina 29808 
(803) 208-3592, robert.watkins@srs.gov 
 
A. C. Smith 
Savannah River National Laboratory 
Washington Savannah River Co. 
Aiken, South Carolina 29808 
Proceedings of PVP2006-ICPVT-11 
2006 ASME Pressure Vessels and Piping Division Conference 
July 23-27, 2006, Vancoucer, BC, Canada 
 
PVP2006-ICPVT-11-93375llen.smith@srnl.doe.gov (803) 725 2943, a
 
ABSTRACT 
 
Implementation of packaging and transportation 
requirements can be subdivided into three categories; 
contents compliance, packaging closure, and 
transportation or logistical compliance.  This paper 
addresses the area of contents compliance within the 
context of regulations, DOE Orders, and appropriate 
standards.  Common practices and current pitfalls are also 
discussed.    
 
I.  BACKGROUND 
 
The failure to adequately characterize the contents of 
shipments and adequately prepare packages for shipment 
has resulted in unwanted contamination of receiving 
facilities with consequent adverse and sensational 
reporting by news media, References  1 - 4.  This paper 
reviews the contents compliance issues associated with 
packaging and transportation of radioactive materials. 
 
II.  REGULATIONS   
 
The Code of Federal Regulations (CFR) provides many 1
 https://proceedings.asmedigitalcollection.asme.org on 07/01/2019 Terms of Usedetailed requirements pertinent to the design, fabrication, 
testing, and use of radioactive material packagings.  
Contents compliance is discussed in only a few instances 
in both the Department of Transportation (DOT) 
regulations in Title 49 of the CFR and the Energy 
regulations in Title 10 of the CFR.      
 
A. Transportation 
The DOT regulations discuss contents compliance in 49 
CFR 173.24 General requirements for packagings and 
packages and 49 CFR 173.475 Quality control 
requirements prior to each shipment of Class 7 
(radioactive) materials.   
 
The General requirements section identifies four high 
level concerns about contents and the packaging:  no 
identifiable (without the use of instruments) release of 
hazardous materials, effectiveness of the package will not 
be substantially reduced for minimum and maximum 
temperatures encountered during transportation, no 
mixture of gases or vapors which through any credible 
spontaneous increase of heat or pressure significantly 
reduces the effectiveness of the packaging, and no 
significant chemical or galvanic reaction between package © 2006 by Washington Savannah River Company
: http://www.asme.org/about-asme/terms-of-use
  
 
Dowmaterials and contents of the package. 
 
The Quality control requirements section identifies 
specific areas of concern pertinent to radioactive 
materials.  These include a generic requirement that the 
packaging is proper for the contents to be shipped.  More 
specifically, the quality concerns address the following: 
packaging is in unimpaired physical condition, each 
closure device is properly installed, moderator and neutron 
absorber is present and in proper condition, special 
instructions for filling, closing, and preparation of 
packaging for shipment have been followed, each closure 
is properly closed, and internal pressure of the 
containment system will not exceed the design pressure 
during transportation.  Ensuring radiation and 
contamination limits are satisfied is also addressed. 
 
The intent of the DOT regulations appears to ensure that 
the proper package is used, it is in a working condition, it 
is properly closed and provides necessary containment, it 
will not significantly degrade during transport, and 
credited criticality controls are in place.  Internal package 
temperatures, pressures and potential chemical reactions 
must be considered.        
 
B. Energy 
The Energy regulations in 10 CFR 71.83 and 10 CFR 
71.87 provide requirements that apply to Type B fissile 
packages.  Specifically, 10 CFR 71.83 addresses 
assumptions for unknown properties important to 
criticality safety.  The regulation states that the licensee 
shall package fissile material as if unknown properties 
have credible values that cause maximum neutron 
multiplication.  The severe consequences of a criticality 
event justify the conservative treatment of unknown 
content properties. 
 
The regulations called out in 10 CFR 71.87, Routine 
determinations, are very similar to the ones in 49 CFR 
173.475.  Additional requirements are accessible package 
surface temperatures must not exceed limits in 10 CFR 
71.43(g) and any structural part of the package not 
designed for lifting or tie down must be rendered 
inoperable (i.e., unusable for tie down).  The general 
package performance requirements to withstand 
temperatures and any potential chemical reactions are 
addressed elsewhere in 10 CFR 71.   
 
In general, there is little regulation regarding content 
compliance other than the general statement in 10 CFR 
71.87 (a) that “The package is proper for the contents to 
be shipped”.  The only specific technical guidance applies 
to criticality safety where there is a requirement to 
conservatively estimate unknown quantities.     2
nloaded From: https://proceedings.asmedigitalcollection.asme.org on 07/01/2019 Terms of Us 
 
 
III.  ORDERS AND REGULATORY GUIDES 
 
A. DOE Orders 
The primary DOE Order of interest is 460.1B Packaging 
and Transportation Safety.  This high level order 
establishes the mechanism for DOE certification of 
packages.  Compliance with package certificates are 
addressed in the Requirements portion of the order.  As 
such, contents compliance is addressed as the content 
restrictions are routinely called out in specific detail.  The 
Order does not provide guidance as to how much detail 
should go into a DOE package certificate.    
 
B. Regulatory Guides 
The Nuclear Regulatory Commission drafted Reg. Guide 
7.7 in 1977 titled: Administrative Guide For Verifying 
Compliance With Packaging Requirements For Shipments 
Of Radioactive Materials.  The Regulatory Guide points to  
ANSI N 14.10.3-1975 to provide specific techniques and 
methods for verifying compliance.  
 
IV.  STANDARDS AND PRACTICES 
 
A. ANSI N14.10.3-1975 
This standard provides a method whereby compliance 
with packaging requirements may be obtained and 
documented.  The standard emphasizes protection against 
contamination and radiation exposure incidents.  
Although much of the standard deals with requirements 
other than contents compliance, a checklist is provided to 
address contents issues.  
 
The checklist addresses package degradation due to 
internal reactions (galvanic or otherwise), content 
decomposition, criticality, and additional shielding for 
radiation exposure.  The checklist follows many of the 
requirements for a radioactive materials package as 
addressed in 49 CFR 173.475. 
 
B.  DOE Implementation Guides 
The Radioactive Material Transportation Practices 
Manual (DOE M 460.2-1) establishes a set of standard 
transportation practices for DOE programs.  Section 2.2.1 
states the following: 
Characterization and classification of the material to be 
shipped are necessary to ensure that the material is 
shipped safely and in compliance with applicable 
regulations and that the material is compatible with the 
packaging selected for shipment.  DOE is responsible for 
properly characterizing and classifying the material in 
accordance with DOT requirements and in sufficient © 2006 by Washington Savannah River Company
e: http://www.asme.org/about-asme/terms-of-use
  
 
Downlodetail to permit identification of appropriate packaging.  
Material characterization and classification are 
performed by DOE or contractor technical staff who 
possess detailed knowledge of the material and who have 
been properly trained on the DOT regulations pertaining 
to classification.  
 
The emphasis is on knowing the material well enough to 
select the proper package and ensure regulations are 
adhered to.  Section 2.2.3 addresses packaging selection. 
 
Packaging selection depends on the DOT material 
classification and the chemical and physical 
characteristics of the material.  The shipper is responsible 
for identifying the proper packaging and taking steps to 
ensure that the packagings are available when needed for 
shipment.  For Type B packagings, the appropriate 
certificate of compliance must be checked to ensure that it 
is current and that the proposed contents have been 
approved.  Packaging selection is performed by the 
shipper's or contractor's technical staff who have been 
properly trained on DOT and/or international packaging 
regulations. 
 
The emphasis is on the shipper's responsibility for content 
compliance with the certificate.   
 
C. FIELD EXPERIENCES 
 
The fundamental safety issues for transport of Type B 
packages includes subcriticality, radioactive material 
containment, and radiation shielding. Fundamental 
content characteristics such as chemical and physical 
form, fissile mass, total mass, heat generation, quantities 
of predominant isotopes, curies, A2's, and neutron and 
gamma radiation source are in general reasonably well 
known prior to package loading.  Relatively accurate 
measurements can be made using radiation measuring 
equipment (gamma spectroscopy, neutron multiplicity 
counter, active well counter, ion chambers, neutron 
counters) and calorimeters when plutonium is being 
measured.  In addition, very accurate balances are often 
used to measure nuclear material mass prior to 
confinement packaging.  Additional measurements are 
sometimes made of the total content mass and even the 
loaded package mass. Thus, primary characteristics such 
as mass, isotopic distribution or enrichment, heat 
generation and dose rates of the product containers are 
typically reasonably well known.  However, the complex 
analyses performed in order to rigorously and 
unequivocally evaluate package performance inherently 
lead to detailed specification of what was once considered 
to be a minor content characteristic such as non-
radioactive impurities and presence of very small aded From: https://proceedings.asmedigitalcollection.asme.org on 07/01/2019 Terms of Uquantities of radioactive impurities. These detailed 
specifications of relatively minor constituents are often 
copied directly into the package certificate.  Accurate 
measurement of such constituents on an individual content 
or package basis is often not practical and in some cases 
violates ALARA radiation protection principles.  As such, 
process knowledge is widely used to justify minor 
constituent compliance.  This can lead to inconsistent 
application of "process history" where some package users 
approach is "prove me wrong" while others approach it as 
"we must prove it is compliant". 
 
V.  OBSERVATIONS 
 
Although the regulations provide some high level 
guidance with respect to contents compliance, there is 
minimal guidance outside of the Safety Analysis Report 
(SARP) for a particular package.  The Certificate for each 
package provides the absolute minimum in terms of 
requirements for package compliance.  This can lead to 
inconsistencies and an uneven application of rigor to 
widely varied requirements.  Relatively benign 
requirements such as non-radioactive constituent mass 
limits (e.g limit for iron in the contents) are often captured 
within the content tables which are then pasted into the 
certificate.   
 
One specific area of concern where small quantities of 
highly radioactive materials and even particular non-
radioactive impurities can theoretically impact package 
safety is radiation exposure.  Almost endless permutations 
of simulations can be performed varying and optimizing 
these impurities.  In some cases the models used to predict 
radiation exposure from these mixtures are inherently 
flawed [Ref. 8].  One approach would be to limit the 
content surface dose rate of the item to be packaged based 
upon the shielding protection provided by the package.  A 
nominally bounding shielding analysis would be provided 
in the SARP with a content verification measurement 
required prior to placement into the containment vessel.  
The regulations already require a final post load radiation 
measurement as an additional verification.    
 
Consider the graded approach used to control packaging 
designs for comparison.  Components important to safety 
are designated as "A" or "B" on the "Q" list.  Specific 
features of such items are controlled (e.g. thickness of lead 
shielding, thickness of containment vessel body, gage of 
drum, etc.).  Such components and features are often 
specifically called out in the Certificate.  As such, they can 
not be re-designed without a formal review from the 
certifying official.  Design components and features not 
called out in the Certificate may often be re-designed by 
the package designer provided the change does not 3 © 2006 by Washington Savannah River Company
se: http://www.asme.org/about-asme/terms-of-use
  
Downloadadversely impact package performance, as determined by 
the package designer.   
 
The content descriptions, which are often provided in 
Chapter 1 of a SARP, should include a listing of content 
"safety limits".  Examples of such limits would be fissile 
mass, isotopic restrictions (e.g. enrichment), physical 
form, total heat generation, gross content mass, and 
moderator mass (where appropriate).  Secondary content 
features such as packaging configuration (e.g. types of 
cans), non-radioactive constituents, and relatively small 
quantities of radioactive constituents (e.g. Cs-137 impurity 
within a uranium content) should be generally described, 
but establishing limits and proving compliance is often 
problematic for shippers.  As such, the package designer 
could evaluate and approve minor content deviations as is 
already done to control packaging designs, provided the 
deviation is not prohibited per the package Certificate.  
This approach, in general, would satisfy DOE Order 
460.1B, and it would allow the package designer to 
exercise more authority than is typically allowed.  This is 
justified given the extraordinary transportation safety 
record in the US.  
 
VI.  CONCLUSIONS 
 
Packaging Certificates should specify content parameters 
important to safety, especially in the criticality area.  
However, parameters which are not important to safety 
should not be specified as limits.  Instead, bounding 
assumptions used in the SARP should be identified with 
allowance for revision with approval from the package 
designer. 
 
Shippers must establish internal procedures for confirming 
and documenting the contents they plan to ship. 
 
Strict knowledge of the contents is necessary to select the 
appropriate package for transport of radioactive materials.  
Inadequate contents definition can result in a violation of 
the transportation regulations. 
 
The failure to insure that the contents conforms to the 
packaging requirements can result in imposition of 
additional requirements by regulatory bodies with 
resulting increased operational costs. 
 
All violations of the transportation regulations attract 
media attention which compromises the efforts of the 
nuclear industry to build public support and understanding 
for licensing of long term repositories and resumption of 
power plant construction. 
 
VII.  ACKNOWLEDGMENTS 4
ed From: https://proceedings.asmedigitalcollection.asme.org on 07/01/2019 Terms of Use 
 
The information contained in this article was developed 
during the course of work under Contract No. 
DE-AC09-96SR18500 with the U.S. Department of 
Energy. 
 
VIII.  DISCLAIMER 
 
This document was prepared in conjunction with work 
accomplished under Contract No. DE-AC09-96SR18500 
with the U. S. Department of Energy. DISCLAIMER This 
report was prepared as an account of work sponsored by 
an agency of the United States Government. Neither the 
United States Government nor any agency thereof, nor any 
of their employees, nor any of their contractors, 
subcontractors or their employees, makes any warranty, 
express or implied, or assumes any legal liability or 
responsibility for the accuracy, completeness, or any third 
party's use or the results of such use of any information, 
apparatus, product, or process disclosed, or represents that 
its use would not infringe privately owned rights. 
Reference herein to any specific commercial product, 
process, or service by trade name, trademark, 
manufacturer, or otherwise, does not necessarily constitute 
or imply its endorsement, recommendation, or favoring by 
the United States Government or any agency thereof or its 
contractors or subcontractors. The views and opinions of 
authors expressed herein do not necessarily state or reflect 
those of the United States Government or any agency 
thereof. 
 
IX.  REFERENCES 
 
1. Yeniscavich, W., Review of Ongoing Work at 
Savannah River Tritium Facility, Defense Nuclear 
Facilities Safety Board Memorandum, August 9, 1996. 
2. Steinkuhler, C., and De Smedt, F., Obstacles to and 
Solutions for Transporting Radioactive Materials, Guest 
Editorial, International Journal of Radioactive Materials 
Transport, V 13, N 2, 2002. 
3. Nichols, C. E., Radiological Surveys of Radioactive 
Shipments, Are They Adequate?, Proceedings of the Fifth 
International Symposium on Packaging and 
Transportation of Radioactive Materials (PATRAM), V 2, 
pp 537-539, Las Vegas, 1978 
4. Kallenbach-Herbert, B., and Lange, F., Developments 
in Transport of Spent Fuel in Germany – Measures for 
Contamination Protection, International Journal of 
Radioactive Materials Transport, V 16, N 1, 2005. 
6. Administrative Guide for Verifying Compliance with 
Packaging Requirements for Shipments of Radioactive 
Materials, ANSI Standard N14.10.3, 1975. 
7. Quality Control Requirements Prior to Each Shipment 
of Class 7 (Radioactive) Materials, 49 CFR 173.475. © 2006 by Washington Savannah River Company
: http://www.asme.org/about-asme/terms-of-use
  
 
Downlo8. Boles, J. and Hafner, R., Neutron Source Strength 
Estimates from (alpha,n) Reactions in Binary Mixtures of 
Actinide Particles and Light Element Particles, Paper 
PVP2005-71741, Procedings of the 2005 ASME Pressure 
Vessels and Piping Conference, Denver, 2005. 
 
5 © 2006 by Washington Savannah River Company
aded From: https://proceedings.asmedigitalcollection.asme.org on 07/01/2019 Terms of Use: http://www.asme.org/about-asme/terms-of-use


TYPE B PACKAGE RADIOACTIVE MATERIAL CONTENTS COMPLIANCE

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TYPE B PACKAGE RADIOACTIVE MATERIAL CONTENTS COMPLIANCE

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