X71(06 (8^1 12 G 1 EG3.G TN I 1,10.
012 888 - "WRAPPING" Uf PACKAGES (CASKS) Attachment 3 IN 85-46 June 10,
1985 The question of "wrapping" the exterior of transport packages has
been raised nn SPVPral nrreisinn5, particularly in instances where
"weeping" of contamination has occurred on casks that have been
immersed in spent fuel storage pools prior to transport.
DOT also was qutriad ,:,,,, tlri^, mbttr; by NRC as fulluwy: The issue
of whether exterjdr "wrapping" 9,K casks can be used to achi,fve
c6mplisnct with Yi6ulsrilAirlr i rndommrrrnl,inn l i iL. , leas been
raised on a number of occasions.
Our position on this, with'which I understand you also concur, is as
follows: ° The addition of "wrapping" to an NRC-certified package would
not be permissible without obtaining prior atithnriiatinn of the
mnriifir.ation in tho 3pplicablo NRC z certificate.
In proposing such a provision, an applicant's safety analysis nhviously
would have to address heat L . retention since the contents are a heat
source. ° The "wrapping" of a non-NRC certified package would not
relieve the shipper from compliance with the removable contamination
limits applicable to the exterior surface of the unwrapped package
unless the wrapping constituted an integral part of a DOT Specification
7A, Type A, package dez,iyar.
In such cases, the shipper's'.documentea package infftlf rvni iIAt
lrifti wriiilil iirril t rr rrlilriu i wluii hnn I tin whipm prrrg
woura maintain its closure lntegr^aLy during the normal conditions of
transport.
The reply to NRC by DOT on this matter read at follows: For both
NRC-certified and packages, any wrapping must be addressed in the
package design evaluation.
For NRC-certified packages this would include specific mention in the
certificate of compliance.
For DOT Specification 7A, Type A, packages, the ^Ir^r,her' , Ncu.kaye
5afel.y evaluation woula nave to document the ability of the wrapping
to successfully pass the Type A tests.