DOE O 1540.2, Hazardous Material Packaging for Transport - Administrative Procedures

.. • CI u.s. Department of Energy ORDER , r', I" Washington, D.C. DOE 1540.2 9-30-86 I I SUBJECT: HAZARDOUS MATERIAL PACKAGING FOR TRANSPORT - ADMINISTRATIVE PROCEOORES 1. PURPOSE. To establ1sh administrative procedures for the certification and use of radioactive and other hazardous materials packaging by the Department of Energy (DOE). 2. ~. The proviSions of this Order apply to all Departmental Elements and contractors performing work for the Department as provided by law and/or contract, and as impl emented by the appropri ate contracti ng officer. 3. APPLICABILIT~ The prOVisions of this Order apply to DOE employees and management and operating contractors who are responsible for packaging, shipping, and transporting radioactive and other hazardous materials in off ­ s1 te sh 1 pment ope rati ons. 4. EXCLUSIONS. Packaging for the shipment of complete nuclear explosives, components, and speci al assembl1es 1 s excl uded from the cert1fi cation and approval requi rements of th is Order. (See DOE 5610.1, PACKAGING AND10··'I TRN-ISPORTHG OF NJO-EAR EXPLOSIVES, NJO-EAR COMPONENTS, N-ID SPECIALI . ASSEM3LIES. ) I 5. REFERENCES. i i a. DOE 1540.1, MATERIALS TRANSPORTATION AND TRAFFIC MANN3EMENT, of 5-3-82, which establishes policies and procedures for the management of materials transportation activities, including traffic managemen~ b. DOE 1900.10, FEDERAL REGISTER MANN3EMENT, of 1-31-86, which outl ines responsibilities for the administrative management of ~ederal Register" documents, including approval, promulgation, and certification of all DOE proposed and final rules, regulations, orders, notices, and official documents. c. DOE 5480.3, SAFETY REQUIREMENTS FOR THE PACKAGING AND TRN-ISPORTATION OF HAZARDWS MATERIALS, HAZARDWS SlBSTANCES, AND HAZARDWS WASTES, of 7-9-85, which establishes safety standards for hazardous materials pack­ aging and transportation. d. DOE 5610.1, PACKAGING N-ID TRN-ISPORTING OF NUO-EAR EXPLOSIVES, NUO-EAR COMPONENTS, AND SPECIAL ASSEMBLIES, of 9-11-79, which establishes policy and procedures for packaging and transporting nuclear explosives, nuclear components, and special assemblies. o DISTRIBUTION: INITIATED BY: All Departmental Elements Assistant Secretary for Defense Programs 2 DOE 1540.2 9-30-86 e. OOE 5632.1. PHYSICAL PROTECTION OF CLASSIFIED MAnER AND INFORMATION. of 7-18-79, which describes requirements for the handling of classified information and related matter. f. OOE 5700.6A, QUAL lTY ASSURANCE. of 8-13-81. which establi shes quality assurance standards for OOE operation~ g. 'Uepartment of Transportation Specification 7A Packaging Certification Documen~" of 7-1-85, which provides the certification documentation for the compliance of 7 A packagi ng tested in accordance w 1th the Department of Transportation (OOT) standards. h. Title 10 Code of Federal Regulations, Part 71, '~ackaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions," which establishes Nuclear Regulatory Commission (NRC) safety standards for radioactive mater1 al packagi ng. 1. Title 10 Code of Federal Regulations, Part 871, Air Transportation of Pl utoni um, which establi shes DOE regulations for ai r shi pments of pl utoni um. j. Title 41 Code of Federal Regulations, Parts 109-40, Department of Energy, "Federal Property Management Regulations," which establi shes regulations governing transportation and traffic managemen~

Jk. Title 49 Code of Federal Regulations, Parts 171-179, ";azardous Mater1 al Regulations," which prescribe DOT requirements governing the transporta­ tion of hazardous materi al sin 1nterstate and foreign canmerce. 1. Army lB DOD 700-2, 'Uepartment of Defense Explosives Hazard Cl assi f1cati on Procedures," which prescribes the Department of Defense (DOD) explosives safety requi rement~ m. '![JOE Explosives Safety Manual," w h1ch prescri bes the safety procedures for handling and transporting explosives (available from EH-34). n. International Atan1c Energy Agency Safety Series No. 6. 1973 Rev is10n As Amended, "Regulations For The Safe Transportation of Radioactive Materials," which prescribes the international regulations for the safe transportation of radioactive material~ o. "International Civil Aviation Organization Technical Instructions," 1985 Edition, which prescribes the international requirements for the safe transport of hazardous materi al s by a1 r. c 3 DOE 1540.2 9-30-86 p. "Dangerous Goods Regul at1 ons," International Ai r Transport Assoc1 at1 on, which prescribes safety requirements for the transport of hazardous good~ 6. DEFINITIONS. Definitions contained in DOE 1540.1 and DOE 5480.3 are incorpo­ rated by reference; also see 10 CFR 71 and 49 CFR 100-179 for additional rel ated def 1n1t1 ons. a. Centralized Technical Review Office is a corps of specialists in the necessary engineering disciplines reporting to the Headquarters Certifying Official (herein after referred to as the Certifying Official) to perform technical reviews of DOE Safety AnalYSis Reports for Packaging (SARP's). , b. DOE and NRC Certif1cate of Comp11ance is a certificate issued by DOE or NRC, as appropriate, approving for use with specified limitations a specific packaging for quantities of radioactive materials exceeding AI/A2 quantities as defined in DOE and NRC regulations. c. DOE Contractor 1 s a contractor manag1 ng or operat1 ng a Government-ow ned or -leased facility on behalf of the Department of Energy. d. DOE Alternative is an administrative relief from DOE regulations that meets and prov1 des equivalent heal th and safety protection. C e. DOT Specif1cation packaging is general packaging designed to meet requ1 rements establ1 shed by ooT for hazardous mater1 al s. f. EQu1yalent protection are those alternate measures which will achieve a level of safety at least equal to that specified in the regulations from which the al ternat1ve 1 s sought. will be cons1 stent with the publiC intent. and will provide adequate protection against the risks to life and property. g. Hazardous Materials is a substance or material which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so des1gnate~ These materials are listed in the Hazardous Materials Table, 49 CFR 172.101. h. Hazardous Substance is a material, and its mixtures or solutions, that is identified by the letter ''E" in column 1 of the Table to 49 CFR 172.101 when offered for transportation in one package, or in one transport vehicle if not packaged, and when the quantity of the material therein equals or exceeds the reportable quantity (RQ). This definition does not apply to petroleum products that are lubricants or fuels or to a mixture or solution containing a material identified by the letter "E" in column 1 of the Table to 49 CFR 172.101 if it is in a concentration less than that shown in Figure 1 based on the RQ specified for the materials in column 2 of the tabl e 1 n 172.101.

4 o o DOE 1540.2 9-30-86 RO. Pounds RO. Concentration by weight kilograms Percent PPM 5000•••••• 1000•••••• 100••••••• 10...•.•.. 1........ . 2270 454 45.4 4.54 0.45 10 2 0.2 0.02 0.002 100,000 20,000 2,000 200 20 Figure 1 Reportable Quantities i. Hazardous ~ is any material that is subject to the hazardous waste manifest requirements of the Environmental Protection Agency (EPA) as spec1 f i ed in 40 CFR 262. j. Certifying Official is the deSignated Headquarters official responsible for administering the OOE program for the design review of OOE packagings and issuance of a cert1ficate of compliance upon approval. k. package means, for radioactive materials, the packaging together with its radioactive contents as presented for transport 1. packaging means, for radioactive materi a1 s, the assembly of components necessary to ensure compliance with the packaging requirements of Title 49 CFR, subpart I. It may consist of one or more receptacles, absorbent materials, spacing structures, thermal insulation, radiation shielding, and devices for cooling or absorbing mechanical shocks. The conveyance, tie-down system, and auxiliary equipment may sometimes be deSignated as part of the packaging. m. Radioactive Mater1al is any materi al hav ing a specific activ ity greater than 0.002 microcuries per gram ( Ci/g). n. Safety Analysis Report for packaging is a document that provides a comprehensive techni cal eva1 uation and revi ew of the desi gn, testi ng, operational procedures, maintenance procedures, and quality assurance program to demonstrate compliance with the NRC regulatory safety standards, or equivalent standards established by the OOE for approving packagings and issuing certificates of comp1ianc& DOE 1540.2 5 9-30-86 7. BACKGROUND. This Order standardizes the current approval procedures to ensure that DOE packaging designs and transportation operations provide for public health and safety in accordance with regulations of the DOT and in accordance with standards that are equivalent to the standards prescribed by NRC. 8. POLICY. It is Departmental policy to ensure that all packagings approved for use in transporting radioactive and other hazardous materials meet all appl1cabl e safety requi rements. 9. RESPONSTBILITIES. a. Assistant Secretary for Defense programs (Dp-l). '1) Through the D1rector of Security Eyaluations (Dp-4). (a) Serves as the Certifying Official responsible for administering the program for the review of DOE Safety Analysis Reports for Radioactive Material Packagings for compliance with safety standards and upon confirmation, issues DOE Certificates of Canpliance. (b) Administers the program for DOT Specification 7A certifications. ! :'" (c) Reviews applications for NRC Certificates of Canpl1ance and I t (I. forwards applications to NRC as appropriate. (d) Reviews requests for International Atan1c Energy Agency (IAEA) Certificates of Competent Authority and forwards such requests to the DOT.l I 1 (e) Maintains a central records system at Headquarters for DOE and NRC Certificates of Canpliance and lAEA Certificates of Competent Authority. 1 (f) Develops and promulgates DOE policies and procedures for DOE radioactive materi al s packaging certification.I . (g) Terminates the Certificate of Compliance for a specific packaging for any deficiency that warrants such action. (h) Provides a central point of coordination between DOE Office of Operational Safety (EH-34h DOT, NRC, and lAEA on the 1 nterpretat1 on of standa rds.

(1) Assists public affairs in responding to inquiries related to radioactive material packaging certification and serves as lead in representing and defending DOE before other agencies on 6 o DOE 1540.2 9-30-86 Jissues related to radioactive material packaging certifi~tion policies. (j) Develops and coordinates a training program for packaging certifi cations. (k) Distributes DOE, NRC, and IAEA certificates to Headquarters Elements and operations offices. (1) Maintains the Directory of DOE Certificates of Compliance for Radioactive Material Packagings and the compliance documentation for DOT Spec1fication 7A Type A packagings. (2) Through the D1rectotJPf Defense Waste and Transportat1on Manage.tnt (DP=lZ) • (a) Provides a central pOint of coordination between OOE and operations offices with OOT, NRC, IAEA, and other Federal agencies concerning packaging operational matters. (b) Develops and promulgates administrative procedures for hazardous material packagings for transpor~ (c) Administers the classification and registration program for explosives including the registration progr.am interface with OOL . (d) Assists line program managers in interpreting standards and regulations (DOE, OOT, NRC, and IAEA) for purposes of clarification, including interfacing with these organizations; eval uating the need for new packaging requirementsJ and providing guidance in the preparation of SARP's. (e) In conjunction with responsible line program managers, administers a program to ensure adequate documentation of procedures and implementation of regulations involving radioactive materials packagings; the explosives classification and registration program interface with OOT; and coordination of program packaging activities. (f) Conducts appraisals involving packaging operational functions administered by the operations offices. (g) Plans, develops, and manages the Department-wide program for transportation packaging operations to assure compliance with applicable Federal and international packaging regu1at10n& http:progr.am 7 CI DOE 1540.2 9-30-86 (h) Provides leadership, technical guidance, and advice to other offices of the Department regarding compliance with radioactive and hazardous materials technical packaging standards and regulatory requirements. (i) Assists public affairs and DOE programs in responding to packaging and transportation-related pub1i c or medi a i nqui ries. (3) Through the Director of Safeguards and Security (DP-34), provides assistance in ensuring that classified matter relating to the packaging and transportation operations is administered in accordance with applicable policy, Orders, and procedures. b. Assistant Secretary for Enyironment, Safety and Health (EH-l) Through the Director of Operational Safety (EH-~. (1) Develops and interprets standards for radioactive and other hazardous materials packaging. (2) Ensures that adequate procedures consistent with applicable regula­ tions, standards, and DOE Orders are developed for conducting independent packaging design reviews. o (3) Provides a safety and compliance overview for certification and com­ pliance actions that includes a technical review and analysis of safety considerations for the packaging and transportation of hazar­ dous materi a1 s, hazardous substances, and hazardous wastes. (4) Approves or disapproves requests for alternatives to DOE packaging safety regul ations as requi red by DOE 5480.3

(5) Reviews DOE requests for DOT exemptions, exemption renewals, and party-to-exemptions (PTE), for submittal to DOT. (6) Participates in program planning activ1ties, as requested. (7) Conducts safety overviews covering the imp1ementat1on of DOE packaging safety requirements, 1nc1uding NRC packaging actions; DOT exemptions, renewals, and PTE requests; lAEA packaging actions; inde­ pen,dent technical reviews for packaging compliance and certificat10n aCtions; DOT Type 7A packaging certifications; and special form materials certifications and related actions. (8) Maintains central Headquarters records system for DOE alternative actions; specification packaging actions; and DOT exemptions, renewal s, and PTE requests. 8 DOE 1540.2 9-30-86 (9) Provides a central point of coordination with OOT, NRC, IAEA, and other Federal agencies concerning transportati on safety standards. new or revised packaging and (10) Has final authority to terminate the use of a specific packaging based on safety deficiencies. c. Heads of Headquarters Elements. (1) Provide program technical guidance and assistance and resources in ensuring that safe packaging systems are available for the transpor­ tation of radioactive materials, explosives, and other hazardous materi a1 s. (2) Ensure that operations offices and their contractors are in com­ pliance with OOEts transportation packaging policy, applicable Orders, and regul ati ons. d. Managers of Operations Offices. (1) Formally implement this Order and assign staff responsibility as necessary to accomplish its objectives. (2) Take actions necessary to assure themselves that each SARP supports the application for a OOE Certificate of Compliance, and so state in the operations office transmittal letter to the Certifying Official. (3) Provi de prelimi nary desi gn information for a proposed new packaging design to Headquarters and other operations offices in order to give them an opportunity to assess the potential for their us~ (4) Recommend and provide complete and accurate documentation to designated Headquarters Elements in support of requests for the follow ing approval s: (a) Defense Programs (DP-4) or appropriate Headquarters program element if serving as the applicant: 1 OOE Certificates of Compliance; Z NRC Certificates of Compliance; and 3. IN:.A Competent Authority Certificates. (b) Defense Programs (oP-12) with copies to EH-34: Explosives C1 ass­ ft ica ti ons. J I o DOE 1540.2 9 9-30-86 ~ :~ Ic··1.,. I \ (c) Environment, Safety and Health (EH-34) with copies to OP-I2: DOT Exemptions, Renewal s, and PTE requests. I (5) Request EH-34 approval for alternatives to DOE regulations and procedures, and provide to EH-34 a detailed report of the reasons why the al ternative shoul d be granted.I 1 l I (6) Provide documentation to OP-4 in support of OOT Specification Type i ~ 7A actions and special form materials activities, and ensure that DOE i, contractors comply with the applicable regulations governing these actions and activities. I . I (7) Ensure that contracts under their cognizance which involve the packaging and transportation of radioactive materials and other hazardous materi al s contai n prov isi ons that requi re compliance with this Order. (a) Suspend the use of specific packagings, when directed by EH-34, l OP-I2, or OP-4, as appropriate.

(9) Ensure that contractors provide documentation to the responsible operations office verifying compliance with applicable OOT Spec1fica­ tion Type 7A and Type B requi rements, and compliance with applicabl e sped al form materi al requirements. (10) Ensure that contractors maintain those master records of SARP's for packagings which the contractor submits for certification, and main­ tain on file copies of operating procedures for purposes of distribu­ tion to other DOE users upon request. (II) Ensure that contractors maintain complete documentation files for each Specifi cation Type 7A, Type B, and special form materi al actions for those packagi ngs bei ng used by the contractor. e. Manager of Chicago Operations Office, in addition to the requirements in subparagraph 9d, above, contracts on behalf of the Certifying Official for establishing centralized technical support in the review and evaluation of SARP's for DOE. f. Managers of AlbYQuerQue and San francisco Operations Offices, in addition to the requirements in subparagraph 9d, above: (I) Examine, classify, and approve shipping descriptions and the hazard cl ass for new explosives. (2) Provide documentation to Headquarters (OP-I2) verifying that explosive classifications conform to OOT guidelines. o o o 10 DOE 1540.2 9-30-86 Jg. General Counsel (GC-l) provides advice and assistance relating to Federal, State, and local laws and regulations. h. Aa~tant Secretary for Nuclear Energy (NE-I) Through the Deputy Assistant Secretary for Naval Reactors (NE-60). (1) Assume the responsibilities of operations office managers for the Naval Reactors program. (2) Assume the responsibilities assigned to officials in subparagraph 9a through b,above, for the Naval Reactors program as del i neated be1C1fI : (a) Admi ni ster a program for Naval Reactors (NE-60) packagi ngs including the design review and issuance of DOE Certificates of Compl hnce, approval or di sapproval of requests for al terna­ tives, termi nation of the use of a spec1fi c packaging for any deficiency that warrants such action, and interaction with other Federal agencies as appropriat~ (b) Ensure adequate documentation of procedures, regulations, and requirements involving NE-60 packaging. (c) Conduct appraisals and safety overviews and audits contractor performance in programs related to NE-60 packaging activities. (d) Maintain a central records system for NE-60 packagings and provides copies of Naval Reactors DOE Certificates of Compliance to the Certifying Official (DP-4) for the Headquarters central records system. i. Director of CiVilian Radioactiye Waste Management (RW-l) Through the Director of Transportation and Waste (RW-33). (1) Administers a program to develop packagings certified by the NRC through RW contractors in accordance with Title 10 CFR Part 71 and the requi rements of page 1-2, pa ragraph 3M 2) of th i s Order. (2) Administers a program to ensure adequate documentation of procedures and regulations involving RW-33 packagings. (3) Provides technical guidance and assistance to operations offices for the development of packagi ng systems for RW-33. (4) Develops and maintains a quality assurance program in compliance with Titl e 10 CFR Part 71, subpart H. j 11 (and 12)DOE 1540.2 9-30-86 (5) Ensures that RW packaging design contractors have completed and documented objective and independent eval uations for SARP's prior to the contractor's submission to the NR~

(6) Provides design information and briefings relative to the development of new RW packagi ng desi gns to Headquarters and operati ons offices; coordinates potential cask designs with other DOE requirements; and evaluates potential packaging applications by other operations office& i (7) Maintains central records system for RW-33 packagings and provides I . copies of NRC Certificates of Compliance to the Certifying Official for the Headquarter's Central records system. I . , 10. IMPLEMENTING ADMINISTRATIVE PROCEDURES AND INSTRUCTIONS. a. Chapters I through XII provide detailed administrative procedures and instructions relating to hazardous materials packagin~ b. OOE 54803 i ncl udes the techni cal procedures appl1 cabl e to the preparation of safety anal ysi s reports for packagi ng (SARP's). BY ORDER OF THE SECRETARY OF ENERGY: ~ HARRY L. PEEBLES ~ Director of Administration c o 0 J • i I I ~ o ~ 1 I I 1 j I I I i 0 i DOE 1540.2 9-30-86 TABLE OF CONTENTS CHAPTER I - GENERAL 1. Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 2. Applicability••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 3. Use of DOE, NRC, and DOT Approved Packaging••••••••••••••••••••••••••• a. DOE-Approved Packag1ng•••••••••••••••••••••••••••••••••••••••••••• b. NRC-Approved Packagi ng•••••••••••••••••••••••••••••••••••••••••••• c. DOT Specification Containers•••••••••••••••••••••••••••••••••••••• d. OOE Orders•••••••••••••••••••••••••••••••••••••••••••••••••••••••• CHArTER II - DEPARTMENT OF ENERGY CERTIFICATES OF COMPLIANCE 1. Pu rpose••.......••••.••....•••••••.....••••••••.....•.••.•......•.••.. 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• a. Preparation of Safety Analys1s Report for Packaging by Contract.o r ••••••.•.•••••••••••••••••••••••..••••••••••.••. Figure 11-1 - DOE Certificate of Compliance•••••••••••••••••• Figure 11-2 - Sample DOE Cert1ficate of Compliance••••••••••• b. Internal Review of SASP by Contractor••••••••••••••••••••••••••••• C. Submittal of SASP to Operations Office•••••••••••••••••••••••••••• d. Submittal of SASP to DOE Headquarters••••••••••••••••••••••••••••• e. Review of SASP by the Certifying Official ••••••••••••••••••••••••• f. Preparation and Issuance of Cert1ficate of Compliance••••••••••••• g. Distribut10n of Certificates of Compliance and Supporting Documents•••••••••••••••••••••••••••••••••••••••••••••••••••• h. Expiration Date••••••••••••••••••••••••••••••••••••••••••••••••••• i. DOE Certificate of Comp11ance Processing Times •••••••••••••••••••• j. Renewal of Certificates of Comp11ance••••••••••••••••••••••••••••• k. Cancellation of Certificates of Compliance•••••••••••••••••••••••• 1. Packaging Documentat1on Revisions ••••••••••••••••••••••••••••••••• m. Packaging D1rectory ••••••••••••••••••••••••••••••••••••••••••••••• CHAPTER III - DEPARTMENT OF TRANSPORWION EXEMPTIONS 1. Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• a. Requ1rements for Use of DOT Exemptions•••••••••••••••••••••••••••• b. Requests for Exemptions, Renewals, and Party-to-Exemptions •••••••• (1) Exemptions Requests •••••••••••••••••••••••••••••••••••••••••• (2) Renewal Requests••••••••••••••••••••••••••••••••••••••••••••• (3) Party-to-Exempt1ons Requests •••••••••••••••••••••••••••••••••

c. Expiration Date Requirements •••••••••••••••••••••••••••••••••••••• d. Records••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• I-I 1-1 1-2 1-2 1-2 1-3 1-3 II-I II-I II-I II-2 II-3 II-4 II-4 II-4 II-4 II-S II-a II-9 II-9 II-9 II-10 II-10 II-I0 I II-I III-1 III-1 II1-1 III-1 III-2 1II-2 II1-2 II1-2 o ii DOE 1540.2 9-30-86 e. DOT Exemption Processing Times•••••••••••••••••••••••••••••••••••• f. Make, Mark, and Manufacturer's Exemptions ••••••••••••••••••••••••• CHAPTER IV - DEPARTMENT OF ENERGY ALTERNATIVES I. Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 2. Procedu res...•••..........•••••••.•...••.•••........••••.•.....•..•••• a. Requirements for Use of DOE Alternatives•••••••••••••••••••••••••• b. Requesting Offices•••••••••••••••••••••••••••••••••••••••••••••••• c. Submittal of Requests••••••••••••••••••••••••••••••••••••••••••••• d. Reports••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• e. Documentation Requirements •••••••••••••••••••••••••••••••••••••••• CHAPTER V - NUCLEAR REGULATORY COMMISSION CERTIFICATES OF COMPLIANCE 1. Purpose.••... 4It;.•••••••••••••••••••••••••••••••••••••••••••••••••••••••• 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• a. Requirements for Use of NRC-Certified Packagings •••••••••••••••••• b. Requests for NRC Certificates of Compliance ••••••••••••••••••••••• c. NRC Licensee Use of DOE-Certified Packagings •••••••••••••••••••••• d. Requests for Renewal of NRC Certificates of Compliance•••••••••••• CHAPTER VI - INTERNATIONAL ATOMIC ENERGY AGENCY CERTIFICATES OF COMPETENT AUTHORIU 1. Purpose...•.....•.••...•....•.••••.•....•..•••••.....•...•••.......... 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• a. Req u 1 rernents •••••••••••••••••••••••••••••••••••••••••••••••••••••• (1) Degrees of Approval •••••••••••••••••••••••••••••••••••••••••• (a) Multilateral Approval •••••••••••••••••••••••••••••••••••• (b) Unilateral Approval •••••••••••••••••••••••••••••••••••••• (2) Type B Packaging Categories •••••••••••••••••••••••••••••••••• (a) Type B(M) Packaging•••••••••••••••••••••••••••••••••••••• (b) Type B(U) Packaging•••••••••••••••••••••••••••••••••••••• (3) Types of Certificates•••••••••••••••••••••••••••••••••••••••• (a) IAEA Certificate of Competent Authority •••••••••••••••••• (b) U.S. Certificate of Competent Authority•••••••••••••••••• (c) Validation Certificate••••••••••••••••••••••••••••••••••• (4) Functions Requiring Certification•••••••••••••••••••••••••••• (a) Packaging Design Approval •••••••••••••••••••••••••••••••• (b) Export Shipment Approval and Notification•••••••••••••••• b. Competent Authority Approvals ••••••••••••••••••••••••••••••••••••• c. International Approvals ••••••••••••••••••••••••••••••••••••••••••• (I) General Import/Export Requirements ••••••••••••••••••••••••••• (2) DOE Use of IAEA-Certified Packaging •••••••••••••••••••••••••• (3) IAEA Certificate Requirements•••••••••••••••••••••••••••••••• 111-2 111-2 IV-I IV-I IV-I IV-I IV-I IV-I IV-I V-I V-I V-I V-I V-2 V-2 VI-I VI-l VI-I VI-l VI-I VI-I VI-I VI-I VI-l VI-2 VI-2 V 1-2 V 1-2 VI-2 VI-2 V 1-2 VI-2 V1-3 V1-3 V1-3 VI-4 J J DOE 1540.2 iii 9-30-86 (a) Design Approval - Export••••••••••••••••••••••••••••••••• VI-4 (b) Design Approval - Import/Export•••••••••••••••••••••••••• VI-4 (c) Export Shipment Approvals for Type B Packagings •••••••••• VI-S (d) Export Shipment Notifications•••••••••••••••••••••••••••• VI-S (e) Special Form Certifications•••••••••••••••••••••••••••••• VI-S

CHAPTER VII - DEPARTMENT OF TRANSPORTATION SPECIFICATION 7A PACKAGING CERTIFICATION 1. Purpose.............................................................. . VII-l I I 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• VII-l a. Ef fact1ve Dates .................................................. . VII-l b. Certification Documents••••••••••••••••••••••••••••••••••••••••••• VII-l c. Documentation for New DOT Specification 7A Packaging Procurements. VII-l d. Records••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• VII-l I CHarTER VIII - DEPARTMENT OF TRANSPORTATION TYPE B SPECIFICATION PACKAGING 1. Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• VIII-l 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• VI II-I a. Requ1 rernents •••••••••••••••••••••••••••••••••••••••••••••••••••••• VI II-I b. Records ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• VIII-I c. References •••••••••••••••••••••••••••••••••••••••••••••••••••••••• VI II-I CHAPTER IX - SPECIAL FORM CERTIFICATION 1. Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• IX-l 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• IX-l a. Requi rernents •••••••••••••••••••••••••••••••••••••••••••••••••••••• IX-l b. Preparation Procedures •••••••••••••••••••••••••••••••••••••••••••• IX-l (1) Effective Dates•••••••••••••••••••••••••••••••••••••••••••••• IX-l (2) Dissemination of Documentation ••••••••••••••••••••••••••••••• IX-l (3) Compliance Certificate••••••••••••••••••••••••••••••••••••••• IX-2 (4) Records•••••••••••••••••••••••••••••••••••••••••••••••••••••• IX-2 CHAPTER X - PACKAGING FOR NOH-RADIOACTIVE HAZARDOUS MATERIALS, HAZARDOUS SUBSTANCES AND HAZARDOUS WASTES 1. Pu rpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• X-I 2. Proced u res•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• X-I a. DOT Packaging Specifications •••••••••••••••••••••••••••••••••••••• X-I b. Requirements•••••••••••••••••••••••••••••••••••••••••••••••••••••• X-I iv DOE 1540.2 9-30-86 CHAPTER XI - EXPLOSIVES CLASSIFICATIONS L Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• XI-l 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• XI-l a. b. New Explosives Requirements ••••••••••••••••••••••••••••••••••••••• Classification of a New Explosive••••••••••••••••••••••••••••••••• (1) Req uests.....................................•............... (2) Criteria••••••••••••••••••••••••••••••••••••••••••••••••••••• (3) Admin1strative Flow•••••••••••••••••••••••••••••••••••••••••• XI-l XI-l XI-l XI-l XI-2 c. Shipment of Laboratory Samples•••••••••••••••••••••••••••••••••••• (1) Req uests................•.................................... XI-3 XI-3 d. (2) Criteria••••••••••••••••••••••••••••••••••••••••••••••••••••• Shipment of Materials for Testing••••••••••••••••••••••••••••••••• XI-3 XI-3 (1) (2) Written Statement ••••••••••..•••••••••••..••••••••.•••.••.••• Criteria••••••••••••••••••••••••••••••••••••••••••••••••••••• XI-3 XI-3 (3) Adin1n1 strat1on••••••••••••••••••••••••••••••••••••••••••••••• XI-4 CHAPTER XII - RULEMAKING REQUESTS FOR HAZARDOUS MATERIAL pACKAGING L Purpose••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• XII-l 2. Procedures•••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• XII-l a. b.

Changes Initiated Outside DOE••••••••••••••••••••••••••••••••••••• Changes Initiated Within DOE•••••••••••••••••••••••••••••••••••••• XII-l XII-l J DOE 1540.2 I-I 9-30-86 QiAPTER I GENERAL 1. PURPOSE. The administrative procedures prescribed in Chapter II through Chapter XII of this Order summarize the actions associated with the review and approval of packagings for the transportion of radioactive and other hazardous material s. 2. APPLICABILITY. a. The provisions of this Order are applicable to packagings used for transporting radioactive and other hazardous materials. Specifically these procedures cover: (1) DOE Certificates of Compliance; (2) DOT exempti ons; (3) DOE alternatives; (4) NRC Certificates of Compli ance; 0 (5) IAEA Certificates of Competent Authority; (6) DOT Specification 7A Packaging Certification; (7) DOT Type B Specification Packaging; (8) Special form certification; (9) Other hazardous materials packaging; (10) Explosives Classifications; andII . (11) Rulemaking requests. I ! t b. This Order also includes the procedures to be followed in performing reviews based on DOE safety evaluations and certificates of complianc~ The Order detal1 s the review and approval procedure that provides a basi s I for DOE to continue to assure DOT, NRC, and others not only that DOE packaging designs meet the regulations, but that the certification processI is equivalent to that of NRC. I c 1-2 DOE 1540.2 9-30-86 3. USE OF DOE, NRC, AND DOT APPROVED PACKAGING a. DOE-Approved paCkaging. Operations offices and DOE contractors may use any packaging whose design has been cert1f1ed by DOE, provided the user shall: (1) Possess a copy of the latest DOE Certificate of Compliance; (2) Possess a copy of the SARP or at a minimum a copy of the drawings and operating and maintenance instructions for the specific packaging; (3) Comply with all actions and restrictions specified in the documents descr1 bed above; (4) Ensure that the organization is registered as a user of the packaging with the Certifying Official; and (5) Ensure that a quality assurance program is established to meet the requirements of the packaging. All contractors must be required to establish and ma1 ntai n an appropriate quality assurance and maintenance program to ensure that DOE-certified packagings in use continue to meet the provisions of the certification and SARP. b. NRC-Approved paCkaging. J(1) DOE contractors may use any NRC-certified packaging provided: (a) The packaging is used in accordance with the limitations specified in the certificate of compliance. (b) The use of the packaging is not prohibited by DOE 5480.3. (c) The contractor complies with the requi rements of page V-I, paragraph 2a. (d) The DOE is registered as a user, and the contractor possesses a copy of the latest NRC Certificate of Comp11ance. (2) All requests for NRC Certificates of Compliance by operations offices and/or their contractors shall be directed to DP-4 in accordance w1th Chapter V. If any of the above organizations contract with an out­ side contractor to develop and obtain an NRC-cert1f1ed packaging, the request for the certificate of compliance need not be coordinated through DP-4 provided that the operat10ns off1ce or DOE contractor does not part1cipate in obtaining the NRC cert1f1cat1on. However, DP-4 should be furnished preliminary design information so as to avoid any duplication of effort and for distribution to other

• • DOE 1540.2 1-3 (and 1-4) 9-30-86 o Departmental Elements having a potential interest. All requests for the registering Departmental Elements as a user of a NRC-certified packaging must be through DP-4. (3) Each operations office shall ensure that their contractors establish and maintain an appropriate quality assurance and maintenance program to ensure that NRC-certified packagings in use continue to meet the provisions of the certification and SAR~ Each operations office will be eval uated on its contractor's transportation quality assurance and maintenance program as part of the Headquarters packaging and transportation appraisal. c. DOT Spec1f1cat10n Conta1ners. Packaging designs which have been published 10 the OOT Hazardous Materials Regulations (Title 49 CFR, Parts 171-178) as specification packagings may be used by operations offices and contractors provided that all provisions of the OOT specification and applicab1 e quality assurance requirements (equivalent to those defi ned in Title 49 CFR, Part 173) are met, and provided that use of the packaging is not prohi bited by OOE 54803. d. DOE Orders. OOE 1540.1 and 54803 requi re that all packagi ng systems meet safety standards that meet OOT packaging standards and are equivalent to the applicable NRC packaging standards. The administrative requirements in OOE 1540.1 and technical requirements in OOE 54803 will provide Departmental evaluators with a consistent policy, established safety stan­ dards, and interpretations consistent with applicable Orders; Title 49 CFR, Parts 171-199; and Title 10 CFR, Part 71. I I II 0"'" '. I J DOE 1540.2 II-I () 9-30-86 CHAPTER II DEPARTMENT OF ENERGY CERTIFICATES OF COMPLIANCE 1. PURPOSE. The foll ow i ng procedures are to be foll ow ed in i ssui ng DOE Certi fi ­ cates of Compliance for packaging used to transport those radioactive mater1als for which packaging des1gn approval is required by DOE regulation~ DOE F 5822.1 "Cert1f1cate of Comp11ance" (Figure II-l> is the form used for certi fy i ng that a packagi ng desi gn complies with applicabl e DOE requi rements and packagi ng standards. 2. PROCEDURES. Prior to the 1ssuance of a Cert1f1cate of Comp11ance, a SARP shall have been prepared by the packag1ng des1gner 1n the format descr1bed 1n the NRC Regulatory Gu1de 7.9 (Figure 11-2). The following procedures apply to the preparation of the SABP, its subm1ssion to DOE for review and approval, and the preparat10n and distribut10n of the result1ng certificate of canpl iance. a. Preparation of Safety Analysis Report for Packaging by Contractor. () (1) All Type B and fissile material packag1ng designs certified by DOE must be supported by a SARP whi ch demonstrates that the packagi ng desi gn meets the packaging standards specified by DOE 54803. (2) The SABP must include a description "of the proposed packaging in sufficient detail to identify the packaging accurately and provide the basi s for eval uati ng the packagi ng. (3) Detailed 1nstruct10ns for operat10ns and maintenance shall be incl uded. (4) The SABP shall a1 so: (a) Include a descript10n of the quality assurance program for the desi gn, fabri cati on, assembly, testi ng, mai ntenance, repai r, mod1 ficati on, and use of the proposed packaging; (b) Identify established codes and standards proposed for use in package design, fabrication, assembly, testing, maintenance, and use. In the absence of any codes and standards, the applicant shall describe the basis and rationale used to formulate the packaging quality assurance program; and

(c) Identify any specific proviSions of the quality assurance program which are applicable to the part1cular packaging design under cons1deration, including a descr1pt10n of the leak test procedure. II-2 DOE 1540.2 9-30-86 DOE F 5822.1 U,S. DEPARTMENT OF ENERGY (5-85) CERTIFICATE OF COMPLIANCE OMB Approval (Formerly EV-1I181 For Radioactive Materials Packages No. 1910·2000 la. Certificate Number 1b. Revision No. lC. Package Identification No. Ie. Total No. Pages. 0000 o USA/OOOO/B( ) DOE 00 2. PREAMBLE 2a. This certificate is issued under the authority 01 49CFR Part 173.7 (d). 2b. The packaging and contents described in item 5 below, meets the salety standards set lorlh in sub pall E, "Package Approval Standards" and aubpan F, "Package and Special Form Tests" Title 10. Code of Federal Regulations. Part 71, 2c. This certificate does not relieve the consignor Irom compliance with any requirement 01 the regulations of the U.S. Department 01 Transportation or other applicable regulatory agencies. including the government 01 any country through or into which the package will be transported. 3. This cerliflcate is Issued on the baSis of a salety analysis report 01 the package design or application­ (1) Prepared by (Hame and addrtlss): (21 Title and Identification 01 report or application: (3) Date: Safety Analysis Report for Packagina-_M_O...;./_D-,ay::..;/_Y_e_ar_DOE Operations Office (Address) XYZ Company 4. CONDITIONS This certificate is conditional upon the fulfilling 01 the applicable Operational and Quality Assurance requirements of 49CFR parts 100·199 and IOCFR Pari 71, and the conditions sPeCified in item 5 below. 5. Description 01 Packaging and Authorized COntenls, Model Number, Fissile Class, Other COndilions, and References: (a) Packaging (1) Model No.: (2) Description (3) Drawings (b) Contents (1) Type and form of materia 1 (2) Maximum quantity of material per package (c) Fissile Class (d) Conditions (1) Limitations (2) Restrictions REFERENCES !Ia.Daleo'lssuance: MOnth/oay/Vear leb. Expiralion Date: Month/Day/Year FOR THE U.S. DEPARTMENT OF ENERGY 7a. Addreis (of DOE Issuing Office) 7b. Signature, Name, and Title (of DOE Approving Official) US Department of Energy Washington. DC 20545 lsI Headquarters Certifying Official Attention: DP-4 Figure II-I J DOE CERTIFICATE OF COMPLIANCE 11-3 o • DOE 1540.2 9-30-86 INTRODUCTION GENERAL INFORMATION Introduction Package Description STRUCTUfW.. EVAlUATION Structural Design Weights and Centers of Gravity Mec~anical Properties of Materials General Standards for All Packages Standards for Type B and Large Quantity Packaging Normal Conditions of Transport ~pothetical Accident Cond1tions Sped a 1 Form Fuel Rods THERMN.. EVAlUATION Discussion SummarY of Thermal Properties of Materials Technical Specifications of Components Thermal Evaluation for Normal Conditions of Transport Hypothetical Accident Thermal Evaluation CONTAIN~T Containment Boundary Requirements for Normal Conditions of Transport Containment Requirements for the Hypothetical Accident Conditions Io SHIELDItE EVAlUATION Discussion and Results Source Specification Model Specification Shielding Evaluation aUTlCAl. m EVAlUATION Discussion and Results Packa~ Fuel Loading Model Specification Criticali~ Calculation Critical Benchmark Experiments Fi ssl1 e Cl ass OPERATItE ~DURES Procedures for Loading the Package Procedures for Unloadfng the PacKage Preparation of an Empty Package for Transport

AaEPTANa:: TESTS AND MAINTENANa:: f'ROORAM Acceptance Tests Maintenance Program Fi gure II-2 SARP Format II-4 DOE 1540.2 9-30-86 b. Internal Review of SARP by Contractor. (1) DOE contractors shall be required to conduct a formal internal review of the SARP prior to submission to the operations office. (2) Each contractor may make use of outside consultants or other contractors as necessary for a SARP review. A report concerning the review parti ci pants, procedures and methods of rev 1ew, comments and resolutions shall be prepared and available for audit by the responsible operations office. c. Submittal of SARP to Operations Office. (1) After the internal eval uation has been completed and necessary changes have been made to the SARP, the contractor shall be required to submit the final draft of the SARP along with the internal review report to the appropriate operations office. (2) The operations office shall take all actions necessary to assure themselves that the SARP is complete and supports the application for a OOE Certificate of Compliance. d. Submittal of SARP to DOE Headquarters. E1 ght copies of the SARP shall be J submitted by the operations office or the Headquarters program element, as appropriate, to the CertHyi ng Offi c1 al (DP-4) with a supporting memoran­ dum as to the completeness and adequacy of the SARP. e. Review of SASP by the CertifYing Official. The Certifying Official shall: (1) Establish in advance, when necessary, procedures to witness any field performance tests on which the determination of packaging adequacy is based. (2) Formally conduct centralized technical review s of each SARP and ensure that all technical concerns have been addressed and that all corrections resulting from the review are made prior to final publication and distributio~ (3) Ensure that all fabrication inspections and procedures required by qua1i~ assurance plans are identified and include provisions that ensure they will be followed. Inspections during fabrication will be the responsibili~ of the contractor, and the documentation should be available for review by OOE. The vendor's qual i~ assurance records will be subject to review, and the quali~ assurance plan shall be documented in the SARP. J • DOE 1540.2 II-5 o 9-30-86 (4) Ensure that the regul atory requi rements are documented in adequate depth and clarity. (5) At any time require additional information in order to determine if a certificate of compliance should be granted, denied, mod1f1ed, suspended, or revoked. (6) Maintain an auditable record of the review process, procedures used for review, definition of all issues raised, findings, and criteria by which the packag1 ng desi gn was eval uated. f. preparation and Issuance of Certificate of Compliance. (1) Upon com pl eti on of a sat1 sfactory DOE rev iew of the SARP by the Certifying Official, the Official shall prepare and issue a DOE Certificate of Compliance using DOE F 5822.1 (F1gure II-1). Each certificate shall be Signed by the Cert1fy1ng Off1c1al or a formally deSignated representative and shall conta1n at a m1n1mum the information described below. To av01d adm1n1strat1ve problems, the cert1f1cate should not reference any documents that contain classified information or other informat10n that 1s not available to the public. (a) Certificate Number (Block la). A four-d1g1t number w1ll be aSSigned for new cert1f1cates from the follOWing blocks of m.mbers:

NRC: 9001-9500 NR: tJ781-9840 Al..: 9501-9560 NY: 9841-9850 0-1: 9560-9595 OR: 9851-9900 GJ: 9596-9600 R.: 9901-9930 li1: 9601-9760 SAN: 9931-9960 IO: 9761-9780 SR: 9961-9999 , (b) Reyision Number (Block lb). Certificate revisions must be identified 1n block lb. Revisions and revision numbers may be 1ssued only by the Certifying Official. The revised portion shall be highlighted by a "change indicator" mark cons1st1ng of a bold vertical line drawn in the margin opposite the binding marg1n. The 11ne shall be the same length as the portion actually changed. (c) Package Identification (Block lc). This is the ~mbo1 that is marked on the packaging and in the shipping papers in accordance with DOT regul ati ons. The packag1 ng does not need to be remarked for certificate rev1sions 1nvo1v1ng changes 1n authorized contents, exp1rat10n dates, reference document~ or other changes not 1nvolv1ng packaging deSign changes. A o II-6 DOE 1540.2 9-30-86 J significant modification affecting the design and contents may require a revision marking on the packaging exterio~ This number inc1 udes a prefix, a unique identification number, a type code, and a suffix: 1 Prefix. The letters "USA". Z Identification Numbe~ Identical to four-digit number in the block la. 1 Iype Code. A single- or multi-letter deSignation of the type ..of proposed use of the package as follows: A A - Type A package desi gn. (Only used for Type A fi sslle packagi ng.) .b BW) - Type B packagi ng desi gn that fully complies with all regulatory requirements and IPCA regulations. The letter (U) is for IPCA use and means that only unilateral approval by the originating country is required. ~ B(M) - Type B package design that contains some exceptions but meets type B(M) requirements. The letter (M) is for IPCA use and means that mu1 til atera1 approval is requi red '\ between the ori gi nati ng country and the receivi ng country ....., as well as other countries that might be affected by shipments through their territory• .d F - Fissile materials package design. Jl B( ) - Packaging for domestic use (usually 01 der packagings) that have not been evaluated against B(U) or B(M) cri teri a. ! Suffi~ The certificate shall designate that it is for DOE use on1 y. S. Example. USA/9860/B(U)F (DOE). (d) Page Number (Blocks Id and Ie), The cover (si gnature) page 1 s always page 1. The total number of pages in the cert1ficate is noted in block Ie. All pages must be numbered, dated, and identified by the certificate of compliance number. (e) SAaP Identification (Block 3). This identifies the operations office responsi bl e for submittal of the SAAP and to whom the certifi cate shoul d be issued. • • DOE 1540.2 11-7 o 9-30-86 (f) Description of Packaging and Authorized Contents, Model Number, F1ss1le Class, Other Conditions, and References (Block 5). 1 packaging or Vehicle Containment System. A description of the materials of construction, gross weight, general external and internal dimensions, appearance, method of closing, and model number. Z Authorized Contents. A brief description of the physical and chemical forms; the approximate quantities (including radio­ nuclides, if appropriate), in curies; amounts, in grams (for

.. fissile materials); criticality transport index number for fissile materials packages; expected heat removal capacity (in Btu/hr); and any restrictions on the contents that might not be obvious from the nature of the packaging. If appro­ priate, International System (SI) units may be provided par­ enthetically, in addition to English units. Additional pages may be added for additionally authorized contents. Comi n­ gling restrictions for contents should be identified if appropriate. l Limitat10ns and Restr1ctions. This shall include: o £ Any areas in wh1ch the packaging design is not fully in compliance with the DOE regulations; and b Any restrictions on the use of the packaging with regard to modes of transport, types of vehicles, freight containers, or supplementary operational requirement~ Such restrictions may require the issuance of a DOT exemption from some part of the DOT regulation~ ! Other References. Used as required. (g) Dates (Block 6). These dates are the date of issue and the expiration date. The expiration date will be 5 years after approval or less if appropriat~ (h) Approval Signature (Block 7). This Signature shall be the Certifying Official or the Deputy Assistant Secretary for Naval Reactors, as appropriate, or their deSignated representativ~ ( 1) Appendices. Al ternative package contents, other necessary technical data or information, and modifications and amendments shall be li sted in an appendix. The above documents must al so be available for adequate understanding of the limits and use of more complex packaging. c II-8 DOE 1540.2 9-30-86 (2) The Certifying Official shall maintain a master packaging file for each certificate of compliance, containing as a minimum: (a) The final SARPj (b) The operations office application; (c) The latest approved certificate of compliance; (d) Reproducible drawings of packaging showing the general makeup of the packaging and an arti st's concept; ... (e) Applicable operations and maintenance instructions; (f) Quality assurance plan; and (g) Other pertinent information, as appropriate. (3) Each master packaging file shall also contain: (a) Any subseq uent amendments or rev 15i ons to the SARP or certificate of compliance; (b) Results of any subsequent reviews of any amendments or revisions; J (c) Updated list of users for the specific packaging; and (d) Any subsequent modification to the packaging. g. D1stribut1on of certificates of Compliance and Supporting Documents. (1) The Certifying Official shall provide the follOWing distribution: (a) Assistant Secretary for Enyironment. Safety, and Health (EH=34). One copy of the/certificate of compliance. (b) Heads of Headquarters Organizations. One copy of the certificate of compliance. (c) Qperation Offices. One copy of the certificate of compliance. (d) Nayal Reactors. One copy of the certificate of compliance to the Pittsburgh Naval Reactors Office, and one copy to Schenectady Naval Reactors Offic~ II-9DOE 1540.2 9-30-86 (2) The operations office to whom the certificate is issued shall, upon request by other users, be responsible for providing additional documentati on (i.e(' operati ons and mai ntenance procedures, and qual ity assurance pl ans). (3) If an NRC Certificate of Compliance or an IAEA Certificate of Competent Authority is also required, the distribution reqUirements set forth in Chapters V and VI must be followed.

(4) Copies of the SARP or operating and maintenance and drawings normally will be distributed directly by the operations office to their contractors. (5) Classified SARP's shall be forwarded through the cognizant operations office in accordance with applicable security procedures. o h. Exp1ration Date. An expiration date shall be aSSigned to each certificate of compliance. The expiration date shall provide no more than 5 years of validity and should be less if conditions warrant. A blank expiration date will invalidate the cert1ficate. The Certifying Official will reissue within a prescribed period of time to be determined those active certificates of compliance which do not have an expiration date, and otherwise meet the proviSions of this Order. i. DOE Certificate of Compliance processing Time~ The application for a DOE Certificate of Compl iance shall be made on a timely basis. A response to the applicant by the Certifying Official will be provided within 60-90 days from receipt. If additional information is required, timing wl1l depend upon the applicant's response to the Certifying Official's request for information and to subsequent questions which may evolve. .. j. Renewal of Certificates of Compliance • (1) Ninety days prior to the expiration date of a certificate the contractor requesting the renewal shall submit documentation to the Certifying Official through the responsible operations office justifying renewal of the certificate. Such documentation shall include, but not be limited to: (a) The necessity for renewing the certificate; (b) That the SARP has been reviewed and complies with applicable requirements and standards: and (c) A slll'lmary of the history of past usage. (2) Upon review and approval by the Certifying Official a revised certificate with a new expiration date shall be issued. A copy of o (,,)o 11-10 OOE 1540.2 9-30-86 the certificate shall be provided to EH-34. each operations office. and to each user of the certificate (see paragraph 2f(l». (3) Operations offices which do not intend to request renewal of a cert1ficate issued to their organization should notify all other operations offices 120 days prior to the expiration date of the certificate. If another operations office requires the continued use of the packagi ng. that office may request a renewal from the Certifying Official. The request should follow the requirements set forth in subparagraph Hi) above. for renewal of OOE Certificates of Compliance. The new issuing office w111 be designated on the revised certificate. k. Cancellat10n of Certificates of Compl1ance. The use of any certified packaging will be terminated when it is no longer approved by a valid certificate of compliance. Cancellation of OOE Certificates of Compliance shall be made only by the Certifying Official. Recommendations for can­ cellation may be made by any program or operations office. Notification of the reason(s) for cancellation must be provided to the Certifying Official (telephone immediately with follow-up in writing within 10 days). All OOE Elements w1l1 be given 60 days to show cause why the certificate shou1 d not be cancell ed. 1. Packaging Documentation Revisions. (1) Certificate Rev1s10ns. The issuance of a revised OOE certificate is required only for substantive changes to approved packaging design~ Changes in existing certificates of compliance can only be made by the Certifying Official. Requests for revisions may be made by operations offices who must submit the supporti ng documentation required for the Certifying Official to evaluate and to process any authorized revision~ Revisions to certificates shall be highlighted by vertical lines in the right hand margin. ..

(2) SASP Revisions. If changes are made to the approved packaging design. the SASP must be reviewed for possible modification prior to initiating changes to the OOE Certificate of Compliance. These revisions may be implemented through supplements. amendments. or in the case of extensive changes, complete revisions to the SARP. All mod1fi cati ons to the SARP requi re internal revi ew by the contractor and OOE review. Issuance of a revised OOE certificate is required only for substantive changes to approved packaging design~ m. packaging Directory. DP-4 will maintain a directory of OOE Certificates of Compliance for radioactive material packaging~ • III-1DOE 1540.2 9-30-86 CHAPTER III DEPARTMENT OF TRANSPORTATION EXEMPTIONS 1. PURpOSE. The procedures set forth in this chapter are to be used in obtaining DOT exemptions, renewals, and party-to-exemptions (PTE) pursant to Title 49 CFR of the DOT Hazardous Materi al s Regul ati ons. 2. PROCEDURES. a. Requirements for Use of DOT Exemptions. DOT exemptions may be used by DOE and its contractors provided the exemption is either fssued to DOE or DOE is a party to an exemption. The user must possess a copy of the exemption. The user must provide usage data to the operations offfce responsible for maintafning the exemption. b. Requests for Exemptions, Renewals, and Party-to-Exemptions. All requests for DOT exemptions, renewals, and/or PTE's will be made by the originating operations office to EH-34 for review and submission to DOT with a copy to DP-12. o (1) Exemption ReQyests. The conditions under which DOT will issue an exemption are set forth in Title 49 CFR Part 107 of the DOT Hazardous Materials Regulations. All requests for DOT exemptions w111 be submitted in the format required in Part 107. The format for sub­ paragraphs a - d show n below must be used. (a) Submitted to: Office of Hazardous Materials U.S. Department of Transportation Washington, DC 20590 .. ATTN: Exemptions Branch (DMT-231) (b) Regulation Affected: Title 49 CFR Part 173.206. This is a request for an exempti on from the "packag1 ng requi rements of Ii tl e 49 CFR Part 173.206" w hi ch ••• (c) Applicant: U.S. Department of Energy Washington, DC 20545 ATTN: Director of Transportation and Facility Safety, EH-34 Contact: Packaging and Transportation Safety Program Manager, EH-34 (Telephone Number) (d) Proposed Packaging: (a complete description of the proposed packaging) c o 111-2 DOE 1540.2 9-30-86 (2) Renewal Requests. The conditions under which DOT will issue an exemption renewal is set forth in Title 49 CFR Part 107. Requests for renewals should be reviewed by users to determine if an exemption should be renewed. The operations office shall justify the continued need for an exempti on. (a) If the decision is made for renewal, a written summary of usage (number of shipments and shipping experience) will be obtained from all users. The i nformati on w111 be consol idated by the operations office and formatted for submission to EH-34. (b) If an exemption is not to be renewed, written notification must be made to EH-34 and all regi stered users. (3) party-ta-Exempt10ns Requests. The conditions under which an organi­ zation may request to be a party to an exemption are set forth in Titl e 49 CFR Part 107. c. Expiration Date Requirements. Normally exemptions are issued for 2 years. If there is a continuing need for the exemption beyond the expiration

date, a formal renewal of the exemption must be submitted to DOT through EH-34 at 1east 60 days pri or to the expi ration date. PTE's must be renewed every 2 years al so. d. Records. EH-34 maintains a master file of exemptions used by DOE. Each J operations office maintains records of usage for each exemption for which they are responsi bl e. e. DOT Exemption Processing Times. (1) DOE operations office processing: 30 days. (2) DOE Headquarters processi ng: 30 days. (3) DOT processing. (a) New exemption: 120 days. (b) Timely renewal: 60 days. (Timely renewal requires appl ication to DOT at least 60 days prior to the expiration date.) (c) Party-to-exemption: 30 days. f. Make, Mark, and Manufacturer's Exemptions. These are DOT exempt10ns granted to packaging manufacturers and related to specific packagings and camtodities. o DOE 1540.2 111-3 (and 111-4) 9-30-86 (1) Anyone may use packagi ngs covered under these exemptions; however, it may be necessary that a copy of the exemption accanpany a shipment. (2) Users should be alert to the specific restrictions outlined in the exemption. (3) The administrative procedures for renewal of an exemption include publication in the Federal Register only. DOE users should contact the exemption holder or EH-34 to determine that the exemption is still valid. If the exemption to the manufacturer expires that packagf ng cannot be used. o J DOE 1540.2 IV-1 I I 9-30-86 _ 1'0""I CHAPTER IV DEPARTMENT OF ENERGY ALTERNATIVES 1. PURPOSE. The procedures prescr1bed in this chapter are to be followed in granti ng al ternat1ves to req u1 raments set forth in DOE 54803 for shi pments made via government-ow ned conveyances operated by DOE employees or authorized DOE contractor personnel. 2. PROCEDURES. a. Requirements for use of DOE Alternatives. The DOE alternative must be issued to the operations office applying for the alternative to support a shipment or series of shipments by designated DOE contractor(s). The user must have a copy of the DOE al ternative. b. Requesting Offices. The operations office requesting an alternative is responsible for meeting the requirements set forth in DOE 54803. Such alternatives must provide for protection equivalent to those prescribed by DOT regulations. c. Submittal of Requests. All requests for new DOE alternat1ves must be submitted to EH-34 at least 120 days prior to the need date. Each request for an alternative must specify an expiration date not to exceed 2 years. If there is a need for the DOE alternative beyond the expiration date a formal renewal request must be submitted to EH-34 at least 90 days prior to the expiration date. EH-34 shall review the request and approve or di sapprove an al ternative. Upon approval the DOE a1 ternative w111 be assigned a sequential identifying number and the requestor notified that the alternative is approved. A copy of the approval and backup data will be provi ded to DP-12. An alternative is consi dered under timely renew al and remains in effect provided the renewal request is received by EH-34 at least 60 days prior to the expiration date. d. Reports. Within 30 days after granting or denying an alternative, EH-34 shall provide in accordance with sub-paragraph a, above, a detailed report of the reasons for granting the alternative. e. DQCumentation Requirements. The DOE alternative shall: (1) Set forth the text or substance of the regulation from which the DOE a1 ternative is sought.

(2) State the name, address, and telephone number of the applicant. (3) Include a detailed description of the proposal, including when appropriate: drawings; plans; calculations; procedures; test results; o o IV-2 DOE 1540.2 9-30-86 previous alternatives; approvals or permits; a list of specification containers; a list of modified specification containers to be used; a description of the modifications; and a~ other supporting i nformati on. (4) State the chemical name, common name, hazard cl assification, form, quantity, properties, and characteristics of the material covered by the proposal, including composition and percentage (specified by volume or weight) of each chemical, if a solution or mixtur~ (5) Oescribe all relevant shipping and accident experience. (6) Specify the proposed mode of transportation, identify a~ increased risks that are likely to result if the DOE alternative is granted, and specify the safety control measures which the applicant considers necessary or appropriate to compensate for those increased risks. (7) Specify the proposed duration or describe the proposed schedule of events for which the DOE alternative is sough~ (8) State why the applicant believes the proposal and safety control measures specified therein by the applicant will achieve a level of safety which: (a) Is at least equal to that specified in the regulation from which .J the DOE alternative is sought; or (b) If the regulations do not contain a specified level of safety, will be consistent with the public interest and will adequately protect against the risks to life and property which are inher­ ent in the transportation of hazardous materials in commerce. (9) The DOE alternative must conta in the statement, ''Shi pments must be made via public vehicles or aircraft operated by DOE employees or authorized DOE contractor personnel." DOE 1540.2 V-1 o 9-30-86 CHAPTER V NUCLEAR REGULATORY COMMISSION CERTIFICATES OF COMPLIANCE 1. PURpoSE. These procedures are to be followed by DOE in obtaining an NRC Certificate of Compliance for DOE packagings. 2. PROCEDURES. a. Reguirements for Use of NRC-Certified Packagings. Packaging for which the NRC has issued a certificate of compliance may be used by DOE and DOE contractors without further review and certification, provided that the Department is registered as a user or the certificate is issued to DOE, and that all of the conditions of the NRC certificate are met, and the use of the packaging is not prohibited by DOE 54803. Specifically, the using contractor shall: (1) Possess a copy of the latest NRC Certificate of Compliance; (2) Possess a copy of the operating and maintenance instructions as specified in the license application for the packaging; and o (3) Have an established quality assurance program equivalent to 10 CFR Pa rt 71, subpa rt H. b. Requests for NRC Certificates of Compliance. (1) Applications for an NRC Certificate of Compliance shall comply with the requi rements of Titl e 10 CFR, subpart D and be in the format described in the NRC Regulatory Guide 7.9. (2) Upon completion of the DOE packaging review and approval process, the request, eight copies of the SARP (in addition to the eight copies of the SARP required for DOE certification), DOE certificate of compliance, applicable draw ings, and the DOE eval uation report. shall be forwarded to the Certifying Official for til ing with the NRC.

(3) All formal communications between operations offices or their contractors and NRC or DOT regarding certifications will be transmitted through DP-4. (4) Headquarters processing times for requests for NRC certificates range from 14 to 30 days, depending upon the complexity and the issues associ ated with the packagi ng. NRC processi ng ti mes for new applications are 3 to 4 months to identify issues and 1 to 1 1/2 years for approval if there are issues to be resolved. Amendments require apprOXimately 1 to 2 months to identify issues. o o V-2 DOE 1540.2 9-30-86 J c. NRC Licensee Use of DOE-Certified Packagings. Traffic between NRC li censees and DOE contractors req ui res NRC certHi ed packagi ngs. d. Requests for Renewal of NRC Certificates of Compliance. (1) Appl1cations for the renewal of NRC Certificates of Compliance issued to DOE or its contractors shall be sent to the Certifying Official 60 days prior to the expriration date. Several certificates issued to contractors that are currently valid w1l1 be revised when a renewal is requested. The applications should provide the same information as required for the renewal of DOE Certificates of Compliance (See page II-9, paragraph 2j). DOE cannot request the renewal of an NRC Certificate of Compliance issued to a non-DOE organization unless that organization provides to NRC in wrtting their intent to rel1n­ quish their responsibility as the organization to which the certifi ­ cate was issued. (2) NRC must receive renewal requests 30 days prior to the expi ration date to ensure timely renewal. J o DOE 1540.2 VI-1 9-30-86 o CHAPTER VI INTERNATIONAL ATOMIC ENERGY AGENCY CERTIfICATES Of COMPETENT AUTHORITY 1. PURPOSE. These procedures are to be used to obtain appropriate IAEA approvals for the export/import of radioactive materials shipments. 2. PROCEDURES. a. Requirements. Radioactive material packaging approved for use within the United States (DOE and NRC certificates, and DOT specification packagings) must receive additional approval in the form of a U.S. Competent Authority Certificate for shipments into foreign countries. Similarly, any foreign packaging requires an IAEA certificate and domestic revalidation by the U.S. Competent Authority for sh1 pments into or from the United States. These approval s are in the form of lAEA Certificates of Competent Authority. (1) Degrees of Approval. (a) Multilateral Approval. Approval by both the appropriate competent authority of the country of origin and of each country through or into which the shipment is to be transported. (b) Unilateral Approval. Approval by the competent authority of the country of origin only. (2) Type B Packaging Categories. (a) Type B(M) paCkaging. For international shipments, Type SCM) packaging requires multilateral approval of the packaging design and may require approval of the conditions of shipment. Type SCM) packagings are those Type S packaging designs that have a maximum normal operating pressure of more than 700 kPa (100 psi) guage or a reli ef device that woul d all ow the rel ease of material under accident conditions. Certain countries generally require multilateral approval of most Type B packagings. (b) Type sew packaging. For international shipments, Type S(W packagi ng requi res unll ateral approval onl y (by the country of origin) of the packaging design and of any stowage provisions that may be necessary for heat di ssi pation. The Type SW} package destination will usually require that the packaging meets the IAEA regulations (Safety Series No.6, 1973 Edition, as amended) in all respects.

VI-2 o o DOE 1540.2 9-30-86 (3) Types of Cert1ficates. (a) IAEA Certificate of Competent Author1ty is issued by national competent authorities to certHy packaging suitability and com­ pliance to other authoritie~ (b) u.s. Certificate of Competent Author1ty is issued by the U.S. DOT (the competent authority for the United States) and used by domestfc shfppers to certffy the suitability and compliance of domestic packagfng to forefgn competent authorftfe~ (c) Va11dat1on Cert1f1cate is the multilateral approval for accept­ fng a packagfng approved by a natfonal competent authority. This generally takes the form of an endorsement on the original certificate or the issuance of a separate endorsement. annex. or supplement. A certificate is typically fssued by OOT to certify acceptance of an lAEA certificate received from a foreign compe­ tent authori ty. (4) funct10ns ReQu1ring Certification. (a) packag1ng Design Approyal. A copy of the current U.S. Competent Author1ty Cert1ficate cover1ng the approval of a packaging des1gn 1s sent prior to shipment to the competent authority of .J. each country into or through which the package will be transported (see Titl e 49 CFR Part 172). (b) Export Sh1pment Approval and Not1ficat1o~ The approval and notification defines shipment dates and periods of time for wh1 ch the aproval is sought, contents. i dent1f1 cati on. modes of transportation. type of conveyance, routes, and special controls in effect. This should be delivered to the foreign competent authorities at least 15 days before a shipment is dispatched. If it is a multflateral-approval packaging or one requiring special arrangements because the package does not comply with the lAEA regulations, foreign approvals shall be obtained before the shipment departs the point of origin. b. Competent Authority Approyal s.. Requests for lAEA Certifi cates of Competent Authority should be forwarded to Headquarters (OP-4) with four copies of the supporting documentation 60 days prior to the effective date. (The OOT requires at least 45 days prior to the requested effective date to process the req uest.) J DOE 1540.2 VI-3 9-30-86 c. International A~provals. The DOT is the authorized agency to administer the issuance of international approvals. Foreign packaging of origin may only be used for import/export shipments provided that an IAEA certificate has been issued and a U.S. endorsement has been granted. (1) General Import/Export ReQui rements. Import/Export Shi pm ent s, Domestic or Foreign Packaging (see Title 49 CFR Part 171>. Any radioactive material scheduled for either import into the United States, or export from the United States in the course of being shipped between locations outside the United States may be transported in accordance with IAEA regulations if: (a) U.S. regulations pertaining to shipping papers and placarding are followed; (b) IAEA Competent Authority Certificates and necessary reval ida­ tions are obtained and the requirements of these certification documents are met (Type Band fi ssl1 e packages); (c) Type A packaging is limited to Type A (AI or A2) quantities (see Titl e 49 CFR Part 173); and (d) The country of origin has adopted current IAEA regulations, as amended, and the certificate of compliance states that the packagi ng meets these requi rements. (2) DOE Use of IAEA-Cert1f1ed Packag1n~ Each DOE contractor using a packag1 ng for export whose desi gn has an IAEA cert1ficati on shall be requi red to:

(a) Have a copy of the current U.S. Cert1ficate of Competent Authority (for domestic packaging) or a copy of the U.S. Certification Revalidation (for foreign packaging); (b) Have a copy of the drawings and operating and maintenance instructions for the specific packaging; (c) Comply with the requirements and limitations in the subparagraphs above; (d) Have the package marked with, and the shipping paper contain, the package identification marking indicated on the DOE and NRC approval, or as otherwise indicated by the IAEA certificate; and (e) Prior to first use, ascertain that the DOE is a registered user of the certificate. If DOE is not registered as a user, the appropriate operations office should submit a request to DP-4 to register DOE as a user. o o V I - 4 DO E 1 540 .2 9-30-86 (3) IAfA Certificate ReQuirements. (a) Design Approval - Export. Design Approval for Export of DOE/NRC Approved Packagings (see Title 49 CfR Part 173): 1 To become a user of an existing certificate, DOE shall register as a user of the U.S. Certificate of Competent Authority prior to the first export shipment. All requests w111 be forwarded through DOE Headquarters (oP-4) to DOT. This provision also applies to DOT specification containers for shi pments of radi oactive materi al. 2. Requests for a new U.S. Competent Authority Certificate shall be submitted at least 60 days in advance of a need for a certificate via the responsible operations office to Headquarters (oP-4). Requests shall include four copies of the applfcabl e DOE/NRC Certificate of Compliance and repro­ ducible drawings not larger than 8-1/2 x 11 inches that depict the make-up of the packaging. DP-4 shall forward two copies of the request to the DOT, in such time that it w111 be received 45 days prior to the effective date. 1 The consi gnor shall ensure that a copy of the U.S. Certifi- J cate of Competent Authority has been forwarded to the national competent authori ty for each country into or through which the Type B(M) package will be transported prior to di spatchi ng the shi pment. (b) Des1gn Approval - Import/Export. Desi gn Approval for import/export shipments, including all foreign-made packaging (Type B and fissile materials) must have the IAEA Certificate of Competent Authority revali dated by the DOT before U.s. entry or export is permitted. Thi s may be done at the request of the forei gn competent authority for the country of ori gi n or it may be at the request of a consignee receiving a foreign shipment. The DOE contractor must determine that DOE is registered as a user of a foreign competent authority certificate and the cert1­ fi cates reval1 dati on pri or to export. Normal 1y, thi s regi stra­ t10n w11l automatically occur with the initial request. foreign packagings used for domestic shipments will require the issuance of either a DOE or NRC Certificate of Compliance prior to us~ All correspondence should be routed via the responsible operations office to DP-4. Copies of the certificate and revali dation shoul d be furni shed to the carrier. DOE 1540.2 VI-5 o 9-30-86 o

(c) Export Shipment Approvals for TYpe S Packag1ngs. Any export shipment (domestic and/or foreign packaging) involving vented Type SCM); Type SCM) with highway route controlled quantities; Fissile Class III; or special shipping arrangements requires an applicati on for shi ppi ng approval to be forwarded by DOE Headquarters (in cooperation with DOT) to the foreign competent authority. The notification of approval must be delivered prior to maki ng a shi pment. These requi raments reflect the various independent requi rements of the individual countries that may require additional documentation. The packaging and shipping approvals may be combined into a single approval. Each application for shi pment approval shall incl ude: 1 The period of time for which the approval is requested; Z The description of contents, expected modes of transport, type of vehicle, and proposed route; and 1 The special procedures and administrative/operational controls being implemented in accordance with the deSign certificate. (d) Export Shipment Notificat10ns. Any export shipment of a domes­ tic or foreign packaging involving Type SW) packaging with highway route controlled quantities (see Title 49 CFR Part 173); Type SCM) packaging; Fissile Class III; or special arrangements, requires a notification of shipment initiation to the competent authority of each country involved. Notification must be de­ livered at 1east 15 days before a shi pment starts. The packaging approval, shipping approval, and notification may be included in the same request. The shipper notification in­ cludes: 1 Informati on req ui red for packagi ng i dent1ficati on; and 2 Date of shipment, expected date of arrival, and proposed routing. (e) Special Form Certifications. Under the DOT regulations (see Title 49 CFR Part 173) and the lAEA regulations, radioactive material shipped as "special form" must have been first certi ­ fied by a national competent authority as meeting the lAEA requirements for special form based on encapsulation or physical characteristics. This cert1fication is not required for u.s. domestic shipments, but is required for import and export ship­ ments. The DOT issues cert1fi cates upon req uest. Such requests must contai n the i nformati on req ui red by lAEA regulations and shall be submitted to DOT through the o o VI-6 DOE 1540.2 9-30-86 Jappropriate operations office and Headquarters (OP-4). As a minimum, the request shall contain information as follows: 1 A detailed description of the material or, if a capsule, the contents. Particular reference must be made to both physical and chemi cal forms; Z A detailed statement of the design of any capsule to be used, including complete engineering drawings and schedules of material and methods of construction; and 1 A statement of the tests that have been completed and their results, evidence based on calculative methods to show that the material is capable of meeting the tests, or other evidence that the spec1al form radioactive mater1al meets the requirements of Title 49 CFR Part 173. VII-l (and VII-2) DOE 1540.2 o 9-30-86 CHAPTER VII DEPARTMENT OF TRANSPORTATION SPECIFICATION 7A PACKAGING CERTIFICATIONS I I 1. PURPOSE. These procedures are to be followed in certifying that packagings used for Type Aquantities of radioactive material meet DOT Specification 7A requi rements. I . i ~

2. PROCEDURES. Shippers using Type 7A packagings must maintain on file for at least 1 year after the last shipment, a complete documentation of tests, an engineering evaluation, or comparative data demonstrating that the construc­ tion methods, packaging desi gn, and materi al s of construction comply with the specification. Procedures for the preparation of this documentation are as follows: a. Effective Dates. Type 7A packagings constructed in accordance with the requirements in effect 6-30-83 and prior to 7-1-85 may continue to be used. Packaging deSigned or constructed after 6-30-85 shall meet the requirements then in effecL o b. Certification Documents. Compliance documentation for existing Type A packagings meeting DOT requirements shall be routinely maintained by DP-4 and published in the DOE Certification document for DOT Specification 7A packagi ngs. c. Documentation for New DOT Spec1fication 7A Packaging procurements. It is the responsibility of the contractor to provide to DP-4, through the operations office, any new DOT Specification 7A packaging being developed. DP-4 will provide test results and required documentation for inclusion in the DOE Certification document for DOT Specification 7A packagings. d. Records. The complete documentation file for all Type A packagings, including quality control procedures and documentation shall be maintained by the responsi bl e contractor. The Ty pe A packagi ng records mai ntai ned by DOE operations offices shall include the DOE Certification document for DOT Specification 7A packagings and verification documentation from the supplie~ This documentation shall be used as required to support re­ quests for export/import approval s and exemptions. J J DOE 1540.2 VIII-1 (and VIII-2) 9-30-86 CHAPTER YIII DEPARTMENT OF TRANSpoRTATION TYPE B SPECIFICATION PACKAGING 1. PURpoSE. These procedures are to be followed to assure that DOT Type B specification packagings authorized for Type B quantities of radioactive materials are approved for use by DOE and its contractor~ 2. PROCEDURES a. Requirements. Users of Type B specification packagings must comply with the following provisions of Title 49 CFR: (1) Section 113.413, "Req ui rements for Ty pe B package~" (2) Section 173.416, "Authorized Ty pe B packages." (3) Secti on 113.417, "Authorized Package - Fi ssil e (Type B quantiti es)." (4) Section 173.472, ''Requirements for Exporting OOT Specification Type B and fissile Package~" c b. Records. Appropriate procurement, use, and maintenance files must be maintained by OOE and its contractors who use Type B specification packagings under special conditions, such as: (1) DOT Specification 20WC; (2) DOT Specification 21WC; and f (3) DOT Specification 6M. c. References. Title 49 CFR, Sections 173.413, 173.416, 173.411, 113.474, and 173.475 for Type B requirements, authorized packaging's, and quality control requi rements. o J • J IX-lDOE 1540.2 9-30-86 CHAPTER IX SPECIAL FORM CERTIFICATION 1. PURpoSE. The following procedures are to be used in certifying that special form materials comply with the requirements set forth in Title 49 CFR Part 173, of the DOT regulations. " 2. PROCEDURES. a. Requirements. Each shi pper of speci al form radi oactive materi al shall maintain on flle for at least 1 year after the last shipment is made, a complete safety analysis, including documentation of any tests demonstra­ ting the material meets the requirements for special form. In addition, prior to the first shipment of this material outside of the United States, a certificate of competent authority is required (see Chapter VI>.

(1) "Special Form" radioactive material, is defined in Title 49 CFR Part 173. (2) To qualify as a special form material: o (a) The material must be a single solid piece or contained 1n a sealed capsule that can be opened only by destroying .the capsul e; (b) Have at 1east one di mensi on not 1ess than 5 mi" imeters; and (c) It must meet appl i cabl e test req ui rements. <Title 49 CFR Part 173.) b. preparation procedures. Procedures for preparation of the required documentati on are as follows: (1) Effectiye Dates. Special form encapsulations designed in accordance with 6-30-83 requirements and fabricated prior to 7-1-85 may continue to be used for each type. These encapsulations deSigned and/or fabri cated after 6-30-85 must comply with the appl i cabl e requi rements then in effect. (2) Dissemination of Documentation. It is the responsibility of the procuring contractor to ensure that procurements of special form materials and packagings (capsules) include adequate proviSions for documentation of test results and engineering evaluations. All documentation should be readily available for use by any operations offi ce or contractor. o IX-2 DOE 1540.2 9-30-86 J(3) Compliance Cert1f1cate. Although th1s spec1f1c document is no longer required by OOT, the certificates for existing special form material s or encapsu1 at1 ons will conti nue to be used by OOE. Future encapsulation designs or materials to be used by operations offices or contractors must have a similar level of summary documentation to assist in the administration of applicable design records. (4) Records. The master records for special form materials or encapsulations shall be maintained by the responsible contractor. Records required to support the administration of export/import activities shall be maintained by the responsible DOE operations office and available for overview by appropriate Headquarter's offices. A copy of each record shall be forwarded to the Cert1fying Off1 c1 al (OP-4). J J DOE 1540.2 X-I (and X-2) o 9-30-86 CHAPTER X PACKAGING FOR NON-RADIOACTIVE HAZARDOUS MATERIALS, HAZARDOUS SUBSTANCES, AND HAZARDOUS WASTES 1. PURPOSE. These procedures are to be followed in the selection and use of ~ packaging approved by the Department of Transportation <Title 49 CER Parts 100-179) for hazardous mater1 al s, 1ncl ud1 ng hazardous substances and wastes. 2. PROCEDURES. a. DOT packaging Specifications. Packaging speCifications approved and published by the DOT are authorized for use by Departmental Elements and contractors for transporting hazardous materials other than radioactive materials in accordance with applicable requirements. Procedures for the use of Type A and Type B specification packaging for radioactive materials are provided in Chapters VII and VIII of this Order. b. Requirements. Users shall ensure that packag1ngs constructed in accordance with the DOT specifications meet the current requirements. o (1) Packagings procured from commercial sources must be certified by the manufacturer that the packagi ng meets all appli cabl e specifi cations. (2) It is the responsibility of the user to ensure that adequate documentation is developed and maintained for new spec1f1cat1on packag1ngs constructed for their use. All documentation should be available for audit. c J fl. J J DOE 1540.2 XI-1 9-30-86 CHAPTER XI EXPLOSIVES CLASSIFICATIONS

1. PURpoSE. These procedures are to be followed in assigning DOT hazard classifications for DOE explosive materials, and subsequent DOT registration actions. 2. PROCEDURES. a. New Explosives Reqyirements. New explosives, including explosive com­ pounds, mixtures, or devices (hereinafter referred to as explosives) may be transported if they have been examined, classified, and approved for sh1 pment by DOE. This applies to new explosives made by or under the direction or supervision of DOE. A copy of the approval along with supporting documentation shall be provided to OP-12 for registration with DOT prior to making a shipment. A shipment may be made when the DOE classification has been filed (malled to) with DOT. New explosives that have not been permanently cl assi f1ed may be sh1 pped subj act to the follOWing conditions: (1) To a laboratory for examination, if the requirements of paragraph 2c, below, are met (see Title 49 CFR paragraph 173.86(d». (2) To a testing facility if the requirements of paragraph 2d, below, are met (see Ti tl e 49 CFR paragraph 173.86(e». b. Classification of a New Explosixe. The procedure for apprOVing new explosives or explosive items for transportation in interstate commerce shall be as follows: (1) Reqyests. A written request for a classification action must be prepared stating the proposed classification, method of packaging, .. marking, labeling, and mode of transportation, plus: (a) The request must include the results of the classification tests. (b) If the classification is by analogy, a statement must be included descr1b1ng how the new explos1ve complies w1th the five conditions descr1bed under subparagraph b(2), below. (2) Criteria. Tests are to be conducted accord1ng to the Army DOD TB 700-2 (al ternate tests may be used with j ustificati on) or may be analogous to a previously approved explosive. Analogy data must '\...'-' XI-2 DOE 1540.2 9-30-86 clearly support that the new explosive or explosive item is at least as safe as the previously approved material or item. Specifically, the explosive and package must meet all of the following criteria: (a) The new material does not significantly exceed the previous standard of sensitivity to heat, shock, and energy output; (b) The total quantity is not greater than that contained in the previously classified explosive and is within 3 grams per item; (c) There is no significant change in the configuration in terms of directional energy output or shaping effect, and length-to­ diameter ratio is equal to or lower than the classified item; (d) There is no reduction in the containment characteristics of the outer package, including the container, its latches, banding, and sharp edges; (e) There is no significant decrease in the integrity of the packing material, baffles or separations, orientation, or separation distance, if more than one item is contained in a package; and (f) In some cases the explosive may be shi pped ina variety of specification packaging. If the packaging does not meet DOT J.. specifications, it may be necessary to obtain a DOT exemption. (See Chapter lID. (3) Administrative Flow. (a) The contractor shall submit the request for a classification action along with applicable supporting data to the responsible operations office (either Albuquerque or San Francisco) as appropri ate. (b) Upon review and determination that the request is proper and sufficient, the operations office shall issue a classification

approval document to the req uestor. (c) The operations office shall transmit two copies of the classifi ­ cation approval document and supporting data to DP-12 for filing with DOT. DP-12 will advise the operations office when this filing has been performed via a copy of the transmittal to DOT. The operations office shall then notify the requestor and other affected parties. J c • o XI-3DOE 1540.2 9-30-86 c. Shipment of Laboratory Samples. A new explosive may be shipped via cOOImerci al carrier for the purpose of exami nation pri or to permanent classification approval provided the following actions have been taken: (1) Requests. A written request for tentative classification is prepared stating the proposed classificationl method of packagingl quantity of materiall markingl labelingl and mode of transportation. The request shall incl ude test data or analogy data specified in paragraph 2b(2) above as available and, when not available, discuss and explain the safety measures to be taken for packagi ng and transportati on. (2) Cr1 teri a. (a) A written request for a tentative classification (one copy) with supporting data has been submitted by the contractor to the responsible operations office. (b) Upon review and determination that the request is proper and sufficientl the operation office will issue a tentative shipping descri ption and cl assification ina memorandum to the requestor with a copy to DP-12. d. Shipment of Materials for Testing. A new explosive or explosive item may be shipped via motor vehicle to a test facility prior to having been classifiedl as follows: (1) Written Statement. A formal statement of tentative cl assi ficati on determination shall be prepared stating the proposed classificationl method of packaging, quantity of material, labeling, mode of transportation, and escort provisions. ( 2) Criteria. .. (a) The new explosive is not a forbidden or initiating explosive• (b) The new explosive is a cOOlpound or mixture. It must be described as a high explosive or high explosive liquid as appropriate (other than contained in a device), and packed, marked, labeled, and described on the shipping documents in accordance with applicable ooT regulations. (c) The new explosive is a device. It must be assigned a tentative description and classification by the responsible contractor and packaged, marked, labeled, and described on the shipping docu­ ments as required for tentative descri ptions and classifications by applicabl e OOT regul ati ons. XI-4 DOE 1540.2 9-30-86 J (d) The new explosive is transported in a Government-owned motor veh1 cl e operated by DOE or contractor personnel. (e) The new explosive is accompanied by a person, in addition to the driver of the vehicle, who is qualified by training and experience to handl e explosives. (3) Administration. The written statement shall be prepared and mai n­ •tained by the contractor and the responsible operations office. J • • • DOE 1540.2 XII-1 9-30-86 CHAPTER XII RULEMAKING REQUESTS FOR HAZARDOUS MATERIAL PACKAGING 1. PURpoSE. To provide for a DOE-coordinated position, these procedures are to be follOfed in: a. Q:)mmenti ng on Noti ces of Proposed Rul emaki ng publi shed by the Department of Transportation (Title 49 CFR Part 106) and the Nuclear Regulatory Q:)mmission <Title 10 CFR Part 2); and the Department of Energy (Title 10 CFR, Chapter lID; b. Q:)mmenting on proposed revisions to Safety Series No. 6 by the International Atomic Energy Agency; and

c. Requesti ng Changes to DOT, NRC, or lAEA hazardous materi al packagi ng regulations. 2. PROCEPURES. a. Cbanges Initiated Outside DOE. (1) DP-12 and EH-34 shall review the Federal Regi ster for proposed rul emaki ng i nvol vi ng revi si ons to the hazardous materi al packagi ng regul ati ons.I I (2) DP-12 shall distribute copies of the Notices of Proposed Rulemaking to the field for review and comment. (3) DP-12 will coordinate comments and forward to EH-34 for review andI, ' submission to DOT or NRC as appropriate. (4) DP-12 will coordinate the distribution of proposed IAEA revisions to Departmental Elements and the field for review and comment. b. Changes Initfated Wfthin POE. (1) The originator through the responsible operations office as appropriate shall submit a draft of the proposed rulemaking to DP-12 and the Directives and Federal Register Branch, MA-213.12. I ! f (2) DP-12 shall coordinate with DP-4 and other Departmental Elements as appropriate in reviewing the proposal. (3) DP-12 will submit the coordinated proposal to EH-34 for review and submission to DOT or NRC. '0 1 http:MA-213.12 XII-2 DOE 1540.2 9-30-86 c. These procedures do not apply to Notices of Proposed Rulemak1ng by the Interstate Commerce Comm1 ssion. See DOE 1540.1 • • vU.S. GOVERNMENT PRINTING OFFICE, 1986-181-180,40141