System certification: An alternative to package certification?

One precept of the current radioactive material transportation regulations is that the package is the primary protection for the public. A packaging is chosen to provide containment, shielding, and criticality control suitable to the quantity and characteristics of the radionuclide being transported. Occasionally, radioactive materials requiring transport are not of a mass or size that would allow the materials to be shipped in an appropriate packaging. Where the shipment to be made is relatively infrequent, there may be economic and time penalties that may hamper shipment or force the shipper into uneconomic or high risk options. However, there is recognition of such situations in the International Atomic Energy Agency (IAEA) regulations under the provisions for Special Arrangement. The principal paragraphs defining Special Arrangement in Regulations for the Safe of Radioactive Material; Safety Series 6 (SS6) [IAEA, 1990a] are 141, 211, 720, and 727. In the US regulations the applicable term is ''Exemption.'' An exemption is obtained from either the United States Department of Transportation (USDOT) or the United States Nuclear Regulatory Commission (USNRC) depending on the character of the needed exemption. The essential concept is that some requirements of the regulations that apply in a given situation are not required if the shipment is subjected to other operational controls that provide an equivalent level of risk to that attained if the regulations were observed fully. This paper deals primarily with changing of packaging requirements in Special Arrangements, but it is also true that operational requirements also may be changed as a result of an Exemption or Special Arrangement approval by a regulatory authority