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