U.S. Nuclear Regulatory Commission

Request for Guidance Concerning Use of NRC Certified Casks

HPPOS-152 PDR-9111220116

Title: Request for Guidance Concerning Use of NRC

Certified Casks

See the memorandum from L. B. Higginbotham to L. R. Greger

dated October 19, 1982, and the incoming request from L. R.

Greger dated October 6, 1982. It is acceptable for a

licensee to use an NRC-certified cask as an outer

enclosure. In this case, it is appropriate to obliterate or

cover the certificate identification on the cask exterior

and refrain from referencing the certificate on shipping

papers. HPPOS-064 contains a related topic.

Frequently, licensees ship 55-gallon drums containing LSA

material inside shielded casks. When this is done, the

licensee may consider the drums to be packages and the cask

as a shield to meet the transport vehicle dose rate limits

(10 mr/hr at 2 meters and 2 mr/hr in the cab). IE

Information Notice No. 82-32, Revision 1, acknowledges this

practice and finds it acceptable under the specified

circumstances. However, a telephone conversation with NMSS

prompted this request for clarification concerning the

acceptability of such action when the cask is an NRC

certified package.

Specifically, is it acceptable for a licensee to use an NRC

certified cask in the same manner as an uncertified cask,

as described above, without regard to the certificate of

compliance requirements? If such use is acceptable, must

anything be done to clarify the intended use of the cask,

such as obliterating the cask identification? Obliteration

of the cask identification was suggested by NMSS.

IE has no objection to the use of an NRC certified cask as

an outer enclosure for inside packages, effectively

simulating a "closed transport vehicle, as illustrated in

Appendix B (Left side scenario), IE Information Notice

80-32, Revision 1 (see HPPOS-064). In such a case it would

be appropriate to obliterate or cover over the NRC

certification identification marking on the cask exterior,

and refrain from any reference to the certificate on

shipping orders.

Regulatory references: 10 CFR 71, 49 CFR 173

Subject codes: 7.1, 12.17

Applicability: All