Authorizing the dot specification 6M packaging for continued use at the Savannah River Site

The U.S. Department of Transportation (DOT) Specification 6M packaging was in extensive use for more than 40 years for in-commerce shipments of Type B quantities of fissile and radioactive material (RAM) across the USA, among the Department of Energy (DOE) laboratories, and between facilities in the DOE production complex. In January 2004, the DOT Research and Special Programs Administration (RSPA) Agency issued a final rule in the Federal Register to amend requirements in the Hazardous Materials Regulations (HMR) pertaining to the transportation of radioactive materials. The final rule became effective on October 1, 2004. One of those changes discontinued the use of the DOT specification 6M, along with other DOT specification packagings, on October 1, 2008. A main driver for the change was due to the fact that 6M specification packagings were not supported by a Safety Analysis Report for Packagings (SARP) that was compliant with Title 10 of the Code of Federal Regulations (CFR) Part 71 (10 CFR 71). The regulatory rules for the discontinued use have been edited in Title 49 of the Code of Federal Regulations (CFR) Parts 100 - 185, 2004 Edition and thereafter. Prior to October 1, 2008, the use of the 6M within the boundaries of the Savannah River Site (SRS), called an onsite transfer, was governed by an onsite transportation document that referenced 49 CFR Parts 100 - 185. SRS had to develop an Onsite Safety Assessment (OSA) which was independent of 49 CFR in order to justify the continued use of the DOT Specification 6M for the transfer of radioactive material (RAM) at the SRS after October 1, 2008. This paper will discuss the methodology for and difficulties associated with authorizing the DOT Specification 6M Packaging for continued use at the Savannah River Site.