TRUPACT-III License Exemption Request

The TRUPACT-III is a large, rectangular, Type B(U)F-96 shipping package licensed by the U.S. Nuclear Regulatory Commission (USNRC) for use in transporting large boxes of transuranic waste for the U.S. Department of Energy (USDOE) to the Waste Isolation Pilot Plant near Carlsbad, New Mexico. The package is authorized to transport up to 80W of decay heat. During decommissioning work at a major USDOE site, a tank was encountered that had been used to hold Pu-238 solutions. After cutting the tank in half, each half still held more than 80W of contamination, but because of the risk to personnel, it was decided to seek an exemption from the USNRC to ship the segments without further sectioning. The exemption request sought relief from two regulatory requirements: the authorized decay heat limit shown on the Certificate of Compliance (CoC), and the activity limit of 105 A2 for packages not shown to meet the deep immersion test of 10 CFR 71.61. In the first case, it was only necessary to show that the extra decay heat did not affect the level of safety provided by the package. In the case of the A2 limit, it was necessary to prepare an Environmental Report, because the limit was an explicit requirement of Part 71. This paper describes the purpose of the exemption, its justification, and how it was ultimately obtained.