Attachment 2 

NRC Regulatory Criteria for Transport Package Approval 

The regulatory requirements applicable to spent fuel transportation packages are contained in 

Title 10 of the Code of Federal Regulations (10 CFR) Part 71. In order to be responsive to the 

question on safety criteria, we have summarized the primary safety requirements below. While 

there are additional requirements that must be met, this is intended to provide an overview of 

the three main safety criteria involved in package reviews. According to NRC regulations, an 

application for a proposed package design or amendment to an existing approved package 

design must contain, among other things, a package evaluation. The package evaluation must 

show that the package will meet the appropriate regulatory criteria when it is prepared for 

shipment, and that it will meet the appropriate regulatory criteria after the tests for normal 

conditions of transport and hypothetical accident conditions. 

Criteria for a Package as Prepared For Shipment 

A package must be designed and prepared for shipment, so that under conditions normally 

incident to transportation, the radiation levels do not exceed 2 mSv/h (200 mrem/h) at any point 

on the external surface of the package, and the transport index does not exceed 10. (The 

transport index is the dose rate measured 1 m from the surface of the package.) However, 

spent fuel shipments that are transported by exclusive use (sole use by a single consignor of a 

conveyance for which all initial, intermediate, and final loading and unloading are carried out in 

accordance with the direction of the consignor or consignee) are allowed higher dose rates. A 

package shipped by exclusive use, must not exceed the following dose rates during 

transportation: 

• 2 mSv/h on the external surface of the package, unless the following conditions are met, 

in which case the limit is 10 mSv/h: 

o The shipment is made in a closed transport vehicle; 

o The package is secured within the vehicle so that its position remains fixed during 

transportation; and 

o There are no loading or unloading operations between the beginning and end of the 

transportation. 

• 2 mSv/h at any point on the outer surface of the vehicle, including the top and underside 

of the vehicle; or in the case of a flat-bed style vehicle, at any point on the vertical planes 

projected from the outer edges of the vehicle, on the upper surface of the load or 

enclosure, if used, and on the lower external surface of the vehicle. 

• 0.1 mSv/h at any point 2 meters from the outer lateral surfaces of the vehicle (excluding 

the top and underside of the vehicle); or in the case of a flat-bed style vehicle, at any 

point 2 meters from the vertical planes projected by the outer edges of the vehicle 

(excluding the top and underside of the vehicle). 

• 0.02 mSv/h in any normally occupied space, except that this provision does not apply to 

private carriers, if exposed personnel under their control wear radiation dosimetry 

devices. 

In addition to the above requirements, in the package application the applicant must evaluate 

the tests for both normal conditions of transport (as specified in 10 CFR 71.71) and hypothetical 

accident conditions (as specified in 10 CFR 71.73) and ensure that the package meets the 
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regulatory criteria, as appropriate, after these tests. The effects of the tests may be evaluated 

by physical test, analysis, or a combination of the two. 

Normal conditions of transport 

After evaluating the tests for normal conditions of transport, a package must prevent the loss or 

dispersal of the radioactive contents, maintain the radiation shielding properties, and ensure 

subcriticality. The tests for normal conditions of transport are designed to simulate rough 

handling conditions, which include: falling from a transport vehicle or handling equipment; being 

struck by irregularly shaped freight or other packages with sharp corners; sitting on an 

uncovered loading dock during inclement weather; and having heavy freight loaded on top of 

the package. The tests that simulate the types of damage that could result from these 

conditions are: 

• Water Spray Test, which simulates the package having been left in rain at a rate of 

about 2 inches/hr for a period of at least 1 hour; followed by 

• Free Drop Test of 1 to 4 feet (depending on the package mass) onto a hard surface, in 

the most damaging orientation - simulating falling off a vehicle or loading platform; 

• Stacking Test equal to a force of at least five times the weight of the package for at 

least 24 hours - simulating the damp package being at the bottom of a stack of 

packages; and 

• Penetration Test with a 13 pound, 1.25 inch diameter steel rod being dropped at least 

40 inches onto the damp package - simulating a loose object hitting the package. 

In addition to the rough handling tests, the applicant must evaluate the package for temperature 

and pressure extremes to ensure that ambient conditions will not adversely affect the package. 

After these tests, the package must be demonstrated to have no substantial increase in the 

dose rate, no loss or dispersal of radioactive contents as demonstrated to a sensitivity of 10-6 A2

per hour (see note below for definition of A2) and no substantial reduction in the effectiveness of 

the package. Both a single package and array of packages must be shown to be subcritical. 

Hypothetical Accident Conditions 

The performance criteria that the package designer must use to assess a Type B package 

design against the established hypothetical accident conditions are prescribed in 10 CFR 71.73 

of the NRC regulations and include the following tests, which are to be done sequentially 

(except the immersion test for all packages which may be done on a separate specimen): 

• Free Drop: A 9 m (30 ft) free fall of the test package onto an unyielding surface in a 

position for which maximum damage is expected; 

• Crush: For packages with mass not greater than 500 kg (1,100 lb), overall density not 

greater than 1,000 kg/m3 (62.4 lb/ft3

) and for normal form non-fissile material, contents 

greater than 1,000 A2 - subjecting the test specimen to a dynamic crush test by 

positioning the specimen on a flat unyielding horizontal surface so as to suffer maximum 

damage by the drop of a 500 kg (1,100 lb) steel plate mass from 9 meters (30 ft) onto 

the test package; 

• Puncture: A puncture test as a free drop of the test package from a height of 1 m (40 in) 

onto a 15 cm (6 in) diameter vertical steel peg which has a length as to cause maximum 

damage to the package and is at least 20 cm (8 in) long; 

• Thermal: Exposure to a fully engulfing thermal environment of at least 800o

C (1,475oF) 

for 30 minutes; 
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• Immersion – fissile material: For fissile packages where water in-leakage is not 

assumed in the criticality analysis, immersion of the test package under a head of water 

of at least 0.9 meters (3 ft) in the attitude for which maximum leakage is expected; and 

• Immersion – all packages: Water immersion of the test package under at least 15 

meters (50 ft) depth. 

In addition, packages containing more than 105 A2 must be designed to withstand an external 

water pressure of 2 MPa (290 psi) for a period of not less than 1 hour without collapse, buckling, 

or in-leakage of water (see 10 CFR § 71.61). 

After the tests for hypothetical accident conditions, the package must be subcritical; must not 

have an escape of krypton-85 exceeding 10 A2 in one week and no escape of other radioactive 

material exceeding a total amount A2 in one week; and no external radiation dose rate 

exceeding 10 mSv/h at 1 m from the external surface of the package. 

Note that an A2 is the maximum activity of radioactive material, other than special form material, 

low specific activity, and surface contaminated objects, permitted in a Type A package. Material 

in excess of the A2 value must be shipped in a Type B package that meets the criteria described 

above. This A2 value is either listed in Appendix A, Table A-1, of 10 CFR Part 71, or may be 

derived in accordance with the procedures prescribed in Appendix A. For a package containing 

spent fuel, the A2 value is determined by the formula in Appendix A, which sums the fractions of 

the activity of a radionuclide divided by its A2 value.