The Impact of DOT HM-230 Implementation on Radioactive Material Recovery
J. A. Tompkins, A. Feldman
The implementation of U.S. Department of Transportation (DOT) Rule HM-230 will affect the recovery of unwanted radioactive materials from commercial licensees. The rule was promulgated to harmonize U.S. rules with those of the International Atomic Energy Agency (IAEA). The changes include a new requirement for a criticality safety index (CSI) for fissile material and the phase-out of DOT Type B Specification containers. Changes to the DOT rules also involve the Nuclear Regulatory Commission (NRC), since 10 CFR 71 provides the basis for the DOT rule by reference. The conservative nature of the CSI determination coupled with the cumulative CSI limit of 50 for non-exclusive use shipments will result in significantly higher transportation costs. Orchestration of Pu-239/Be source movements for both consolidation and final disposition will require multiple exclusive use shipments that will be more complex and expensive. The phase-out of DOT Type B specification packaging is most significant with respect to the venerable 6M and 20WC containers, which have been in use since the 1960s. These containers have been the workhorses of those organizations recovering radioactive sealed sources for which there is no current certification of special form status. The 6M and 20WC packages are cost-effective, safe, and have sufficient internal volume to allow shipment of obsolete devices. The issue for the specification Type B containers is not so much one of safety as it is of regulatory compatibility. The long history of the specification containers and their lack of evolution to meet the new standards has created a situation wherein one part of the government is registering and licensing devices that another part of the government is going to effectively prevent from being used for shipping. The current regulatory situation with respect to Type B specification containers is untenable for NRC and DOT. Several solutions are available for the regulators. One solution is an automatic exemption to the phase-out for domestic shipments of devices that are being removed from licensee sites. Another solution is to design and test, at government expense, a new generation of versatile 6M- and 20WC-like shipping containers. Another part of the solution is to inventory and document the number of remaining devices that will require specification shipping containers for cost-effective disposition. It is our recommendation that we take action now, in concert, rather than wait until 2008, when options become limited.
This abstract was presented at the 38th Annual Midyear Meeting, "Materials Control and Security: Risk Assessment, Handling, and Detection", Materials Control and Security Risk Assessments Session, 2/13/2005 - 2/16/2005, held in New Orleans, LA.