NIA submitted a public comment on the Nuclear Regulatory Commission’s Proposed Modernizing Package Certification Requirements Rulemaking. NIA appreciates the staff’s effort to create a performance-based alternative transport package dose rate, but can only support the rule if it is both usable in practice and demonstrably protective of the public.
NRC is proposing to provide greater flexibility for applicants by introducing risk-informed methodologies for demonstrating safety requirements and by “providing an alternative radiation standard for approval of Type B packages for certain exclusive use shipments.” NIA has not previously found a compelling reason to change the radiation standards for transportation. However, NIA could be supportive of the proposed Part 71 optional framework if it is done in a manner that preserves public protection, maintains alignment with other federal agencies, and continues harmonization with international counterparts.