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SSINS No. 6835
IN 86-86
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
October 10, 1986
Information Notice No. 86-86: CLARIFICATION OF REQUIREMENTS FOR
FABRICATION AND EXPORT OF CERTAIN
PREVIOUSLY APPROVED TYPE B PACKAGES
Addressees:
All registered users of NRC certified packages.
Purpose:
This notice is provided to clarify the application of certain provisions of
10 CFR 71 pertaining to the use of certain previously approved Type B
packages. It is suggested that recipients review this information for
applicability to their transportation activities and consider actions, if
appropriate, to preclude any problems for continued use of NRC-certified
packages or Department of Transportation (DOT) specification Type B/Fissile
packages. However, suggestions contained in this notice do not constitute
NRC requirements; therefore, no specific action or written response is
required.
Discussion:
The NRC regulations in 10 CFR 71.13(a) prescribe certain limitations for the
continued use of a Type B package previously approved by the NRC but not
designated as B(U) or B(M) in the NRC certificate of compliance.
1. Fabrication of the packaging must be satisfactorily completed before
August 31, 1986, as demonstrated by the application of its model number
in accordance with 10 CFR 71.85(c).
The above provision is applicable to any packaging where the Package
Identification Number (Item 1.c in the Certificate of Compliance)
includes ..../B( ), .../B( )F or B. It is not applicable where the
Package Identification Number is ..../A or AF.
2. The packaging may not be used for a shipment to a location outside the
United States after August 31, 1986, except under special arrangement
approved by DOT in accordance with 49 CFR 173.471. A similar provision
is included in 10 CFR 71.14(d) concerning use of DOT specification Type
B/Fissile packages.
The above provisions were originally included in 10 CFR 71 for the purpose
of allowing interim use of Type B packages manufactured to designs approved
under provisions of the 1967 Edition of the International Atomic Energy
Agency (IAEA)
8610080068
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IN 86-86
October 10, 1986
Page 2 of 2
regulations for the safe transport of radioactive materials, which were the
basis for 10 CFR 71 before 1983. Only a few of these packages have been
submitted and approved as meeting the requirements of the 1973 Edition of
the IAEA regulations. Subsequent to the 1983 promulgation of the regulations
in 10 CFR 11.13(a) and 71.14(d), the 1985 Edition to the IAEA regulations
was issued. This latest revision of the international regulations provides
for continued acceptance, ,@under certain conditions, of packages approved
under the provisions of the 1967 Edition and the 1973 Edition of IAEA
regulations. Consequently, the need for special arrangements has been
minimized.
The DOT has advised the NRC that after August 31, 1986, certificates of
competent authority, which the DOT issues pursuant to 49 CFR 173.471(d) or
49 CFR 173.472, will include statements explicitly stating the edition of
the IAEA regulations against which the package has been evaluated. A package
evaluated against only the IAEA 1967 Edition and used for export shipment
will be subject to multilateral approval. Current certificates of competent
authority implicitly subject packages to multilateral approval if they are
designated as B( ) or B( )F. Additionally, licensees should recognize that
there may be some countries that may choose not to accept packages approved
only under the 1967 IAEA regulations. In these cases, such country may
accept a special arrangement certificate of competent authority which would
have to be obtained from DOT. To avoid the additional administrative burden
of a special arrangement certificate and to assure the acceptability of
packaging in other countries, it is suggested that package designs be
upgraded to meet the standards of the 1973 or 1985 Editions of the IAEA
regulations.
Please note that the NRC will revise the package identification number to
designate previously approved Type B package designs as B(U) or B(M) after
receipt and review of an application demonstrating that the design meets the
current requirements of 10 CFR 71.
No specific action or written response to this information notice is
required. If you have any questions in this matter, please contact the
appropriate NRC regional office, the DOT contact listed below, or this
office.
Edward L. Jordan, Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contacts: NRC - A. W. Grella, IE
(301) 492-7746
DOT - M. Wangler
(202) 366-4498
Attachment: List of Recently Issued IE Information Notices
Page Last Reviewed/Updated Thursday, March 29, 2012

