A rationale for maintaining the double containment requirement for plutonium shipments

Technical Report · Wed Dec 31 04:00:00 EST 2003

DOI:https://doi.org/10.2172/1184022· OSTI ID:1184022

Channell, James K. ^[1]; Anastas, George ^[1]

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1. Environmental Evaluation Group, Albuquerque, NM (US)

Current U.S. Nuclear Regulatory Commission (NRC) transportation regulations (10 CFR 71.63 (b)) require that all shipments containing more than 20 curies of plutonium must be transported in packages that provide double containment. On April 30, 2002 the NRC issued a proposed rule that would eliminate §71.63(b) and the double containment requirement. NRC’s reasons for proposing elimination of §71.63(b) are: (1) compatibility with International Atomic Energy Agency Transportation Safety Standards (which do not have the requirement); (2) the current rule is inconsistent with the A1/A2 system since it applies only to plutonium; (3) double containment causes a heavier package and results in higher transportation costs; (4) the separate inner containment results in additional radiation exposure; and (5) while there would be additional protection from a separate inner container in an accident; this type of approach is not “risk informed nor performance based.” The Environmental Evaluation Group (EEG) has been a proponent of the double containment requirement for the Waste Isolation Pilot Plant (WIPP) shipments for twenty years. This requirement affects shipments to WIPP much more than any other current or planned shipping campaign because reactor fuel elements, metal or metal alloy, and vitrified high-level waste are exempt from §71.63(b). EEG submitted comments on the Proposed Rule on July 26, 2002 (Appendix C). This report is an update and expansion of the July 26, 2002 comments. Actual WIPP experience with shipments in the double contained TRUPACT-II package is used to respond to NRC arguments for deletion of §71.63(b) and offers a rationale for maintaining the current requirement.

• Research Organization: Environmental Evaluation Group, Albuquerque, NM (US)
• Sponsoring Organization: USDOE
• DOE Contract Number: AC04-78AL10752; AC04-89AL58309
• OSTI ID: 1184022
• Report Number(s): EEG--89
• Country of Publication: United States
• Language: English

Related Subjects

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL PROTECTION