Department of Transportation -- Exemption for using the Transuranic Package Transporter-I (TRUPACT-I) at the Idaho National Engineering Laboratory (Code of Federal Regulations, Title 49, Part 107, Subpart B -- Exemptions, 107-103 Application for Exemption)

Exemption from specific regulations is being sought for the Transuranic Package Transporter Model I (TRUPACT-I) container. The design has successfully undergone extensive testing of a quarter-scale model and a full-scale prototype of the container. Results from the analysis and testing are in the TRUPACT-1 Safely Analysis Report for Packaging (SARP), GA-Al8695/SAND 87-7104 (TTC0735), April 1987 (see Attachment 1). The container was never certified or used because of questions raised during the certification process. Two features of the container design failed to satisfy the regulations for Type B packaging. First, the design utilizes a venting system to control internal and external pressures; this venting system is not allowed by the Code of Federal Regulations, Title 10, Parts 71(h) and 71.51(b) [10 CFR 71.(h) and 71.51(b)]. Second, the maximum quantity fissile material proposed to be hauled in TRUPACT-I exceeded the limits in 10 CFR 71.63(b) for a single-containment container. To correct these design deficiencies, the vents would be plugged during transport, and the maximum quantity of fissile material would be limited to the allowables for a single-containment container. An engineering analysis showed that the container could safely transport radioactive material within the boundaries of the Idaho National Engineering Laboratory (INEL) with the vent system plugged (see Attachment 2). However, some of the requirements for determining pressure on a container need to be changed (i.e., exempted) to reflect conditions unique to the INEL. The following are the requirements needing to be changed for INEL conditions, variances being sought, and justifications for the variances