NRC SFST ISG-20: Transportation Package Design Changes Authorized Under 10 CFR Part 71 Without Prior NRC Approval

Authority for licensees to transport radioactive material comes from 10 CFR Part 71. Licensees
are authorized to transport Type B quantities and fissile materials in NRC-certified packages
under the general license in 71.17. Unlike 10 CFR Part 72, Part 71 does not include change
authority, that is, there is no specific Part 71 regulation that allows licensees to make changes in
the design or operation of an NRC-certified package without prior NRC approval. However,
there is a significant degree of flexibility that may be allowed within the constraints of the NRC
package approval (Certificate of Compliance).
This ISG is intended to clarify the degree of flexibility allowed in package design changes,
including changes in contents and in package operations, without prior NRC approval. One
element that contributes to this flexibility is the level of detail that is included in technical
information that is submitted by an applicant as part of the package application. This is
particularly true of the parts of the application that are incorporated as conditions of the package
approval, such as packaging drawings, contents specifications, package operations, and
maintenance programs. Certificate holders and shippers need to provide sufficiently detailed
information in these parts for NRC staff to perform an adequate technical review; however, the
information should not overly restrict flexibility to make changes without prior NRC approval.