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TRANSCRIPT
xx.xxx-xxxx
Revision 0a DRAFT
Page 1 of 29 Significant Rewrite, Change Bars Not Used
TECHNICAL EVALUATION REPORT
-for-
USA DOT 7A TYPE A DRUMS
COMMERCIAL GRADE ITEM PROCUREMENT
Preparer
Print/Sign/Date
Technical Review
Print/Sign/Date
Supplier Evaluation QA Review
Print/Sign/Date
Other
Print/Sign/Date
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 2 of 29
TABLE OF CONTENTS
Page
REVISION LOG ..................................................................................................................3
TERMS AND ABBREVIATIONS .....................................................................................4
1.0 PURPOSE.....................................................................................................................5
2.0 SCOPE ..........................................................................................................................5
3.0 DISCUSSION........................................................... Error! Bookmark not defined.5
4.0 EVALUATION/SELECTION OF SUPPLIER AND PRODUCT ACCEPTANCEError! Bookmark not defined.7
5.0 DRUM ACCEPTANCE ...............................................................................................8
6.0 TABLES - CONTENT DESCRIPTION ......................................................................8
7.0 REFERENCES .............................................................................................................9
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 3 of 29
REVISION LOG
Revision Date Description
0 Xx/xx/xxx
x
Initial issue.
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 4 of 29
TERMS AND ABBREVIATIONS
ASME American Society of Mechanical Engineers
CC Critical Characteristic
CFR Code of Federal Regulations
CPSA Compliance & Production Sustainability Acceptance
The criteria associated with a supplier’s program and process controls that ensure
compliant production and acceptable performance are sustainable throughout all
completed units.
DOE U.S. Department of Energy
DOT U.S. Department of Transportation
DRV Document Review and Verification.
HMR Title 49, Subtitle B, Subchapter C - Hazardous Materials Regulations
Lot A quantity of items under any given Purchase Order (PO) being simultaneously
produced.
NCT [DOT] Normal Conditions of Transport
PDAT Packaging Design Authority
RE Responsible Engineer; end-user entity (individual or organization) with drum
design, performance, regulatory compliance, etc. technical review and oversight
responsibilities
REA Responsible Engineer Acceptance
SCI Suspect/Counterfeit Item
SCS Supplier Capability Survey
SIS Supplier Implementation Surveillance
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 5 of 29
1.0 PURPOSE
1. This report provides detailed requirements and acceptance criteria applicable to the
procurement of radioactive hazardous materials (rad hazmat) qualified USA DOT 7A
Type A drums as commercial grade items. The drums are to be procured for use as
DOT shipping packaging.
2. This report is intended for use in conjunction with other commercial grade item
procurement documents such as specifications, dedication packages, surveillance
plans, commercial grade survey checklists, and receipt inspection criteria plans.
2.0 SCOPE
Primarily, this report is for use with Supplier’s that do not have fully compliant ASME
NQA-1 2008/2009a (NQA-1) Part 1 quality assurance programs implemented for the
production of drums. However, the itemization of technical requirements and associated
procurement/acceptance criteria may also prove useful when using a graded approach to
procure drums from qualified NQA-1 Part 1 Suppliers.
3.0 DISCUSSION
1. Title 49 Code of Federal Regulations (CFR) qualified, USA DOT 7A Type A drums
(hereafter referred to simply as simply drum(s)) of varying sizes (e.g., 5, 10, 30, 55,
85 and 110 gallon) will be used to contain, store, and transport rad hazmat. Materials
of construction are primarily carbon or stainless sheet steel, fastener hardware,
formed fittings/plugs, cast [closure ring] lugs and gaskets (used to seal lids and bungs
after loading).
2. This document addresses standard “off-the-shelf” single wall, open head, drums with
or without bung fittings, no additional appurtenances (such as valves, lift
attachments, etc.) and no add-on shielding to control radiation dose rates. Contents
will be solids only and suitable for the drum design as determined by the RE. The
7A drums will be procured as qualified for shipment in-commerce or onsite transfer
and with contents as regulated by DOT. Other uses of the drums (i.e., non-DOT
regulated contents) when occurring for onsite transfer under a Transportation Safety
Basis must be uniquely addressed within individual Transportations Safety Basis
documents.
3. Drums are marketed by numerous Suppliers and sold throughout the world to
customers in varying industries. The drums are procured using manufacturer catalog
numbers or generic descriptions such as “DOT 7A Type A meeting 49 CFR 178.350
Requirements”. Production is of a routine, repetitive nature (i.e., processed
continuously by the same personnel, on the same machinery, in the same process
line). Varying design options (such as closure ring type and bung fitting
model/number) are pre-existing and selected “cafeteria style” depending on the
intended use. Unique features that may be requested by an end user are typically of a
superficial of nature (e.g., paint color, interior coating/liner) and should not impact a
drum’s basic design or tested configuration (RE’s responsibility to ensure).
4. The following references (regulatory and DOE directive) are applicable to the
implementation of quality assurance requirements for drum procurements:
49 CFR 173.403 Definitions - Quality
49 CFR 173.474 Quality control for construction of packaging
49 CFR 173.475 Quality control requirements prior to each shipment of Class 7
(radioactive) materials
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 6 of 29
49 CFR 173.415 Authorized Type A packages
DOE Order 460.1C, Packaging and Transportation Safety, Contractor
Requirements Document
NQA-1 is primarily the Standard implemented by DOE contractors for assuring the
quality of procured drums and is the basis for development of this report. However,
within the drum supply industry sales are to customers with varying expectations
related to Supplier quality program standards and most are not for nuclear materials
application. Past experience with drum procurements has revealed that Suppliers will
likely not have a ASME NQA-1-2008/2009a Part 1** quality program or have one
that is not fully implemented. ** Full Part 1 implementation is under a graded approach that includes de-selection of
requirements/sections/paragraphs deemed not applicable to the procured commodity.
Drum manufacturing includes varying activities through completion such as
establishing a regulatory/customer compliant design, ordering multiple material
types/components, prototype testing, fabrication, production testing, and final
assembly. Therefore, Suppliers must have an established QA program with
implemented controls that sufficiently address these activities and ensures product
acceptability whether at some level of NQA-1 implementation or by use of an
alternate quality Standard (e.g. ISO:9001). Details on areas of QA program controls
that will be required of a Supplier for the production of drums are listed in Tables 1
and 2.
5. Drum Safety Functions
Drums are used as 7A Type A packaging in a radioactive materials processing system
that is bounded by 49 CFR Hazardous Materials Regulations (HMR) under normal
conditions of transport (NCT). Included are:
Loading of content and closure to prescribed requirements
Interim/short term staging in preparation for transport
Physical preparation for transport (i.e., handling, lifting and loading/securing on a
conveyance)
Communications for transport (marking/labeling, shipping papers, etc.)
Physical transport from point of origin to point of destination
The Safety Functions of 7A Type A packaging within this processing system are the
safe, reliable, and effective positive closure for containment of materials and, when
applicable, shielding protection from radiation dose rates at or below regulated
levels. Typical drum procurements do not require a design with enhanced or unique
shielding to manage and limit the dose rate. Therefore shielding will not be
considered as a drum safety function in this report.
Note: It is the drum end user’s responsibility through content management and
payload positioning and securement to comply with regulatory radiation dose
requirements.
The HMR contains numerous design, construction, and performance requirements
that contribute to drum use safety. For the purposes of commercial item packaging
dedication, identifiable and measurable attributes most important to drum
performance safety will be selected as critical characteristics (CCs) required for
acceptance. Drum CCs required for acceptance are identified in Table 1 and shall
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 7 of 29
be verified for each delivered lot. Remaining CCs are evaluated for compliance
either during supplier/item suitability assessments, or document reviews. They may
also be required for acceptance with each delivered lot if so determined as required
by the RE. The selection of CCs required for acceptance shall, in part, be influenced
by the Failure Mode description below.
6. Drum Failure Mode
A credible failure mode would be a leaking or unintended opening and exposure to
contents (internal or by spillage) of a drum during NCT (i.e., compromise the
established safety function of protection by positive closure and containment). The
likely failure mechanism for leaking would be at a component to component
mechanical connection such as drum bottom, lid to body interface, or bung fitting.
For unintentional opening and exposure, the likely failure mechanism would be a
loosening or breaking of the drum ring resulting in a partial or complete
seating/removal of the lid.
7. Compliance & Production Sustainability Assessment (CPSA)
CPSA criteria focus on assuring compliant and sustainable Supplier capabilities and
QA program controls. Much of the criteria will be evaluated and validated on the
initial qualification of a supplier and not repeated until performance of periodic
requalification assessments or due to significant changes to customer requirements or
Supplier program controls. Some criteria are more product specific and allow for the
continuing (i.e., with each lot) evaluation/ monitoring of a Supplier’s performance
and quality of product. Reference Table 2 for CPSA criteria.
4.0 EVALUATION/SELECTION OF SUPPLIERS
1. Evaluation/selection of a drum Supplier includes a determination of product
applicability to need as well as suitability for intended use. It will also include
assessing a Supplier’s ability to sustain an acceptable level of product quality.
2. Two criteria from NQA-1 Requirement 7, Section 200 will be used for selection and
evaluation of Suppliers. They are:
Paragraph (b) “qualitative and quantitative evaluation of supplier quality records”
and
Paragraph (c) “direct evaluation of supplier technical and quality capability.”
3. Document Review Verifications (DRV) listed in Table 1and Responsible Engineer
Acceptance (REA) listed in Table 2 align with Paragraph (b).
4. A combination of NQA-1 Part II Subpart 2.14 Acceptance Method 2 (M2),
Commercial Grade Survey and Method 3 (M3), Source Verification from Table 1 and
Supplier Capability Survey (SCS) and Supplier Implementation Surveillance (SIS)
from Table 2 align with Paragraph (c).
5. Use of M2 or M3 for supplier evaluation/selection is in combination with their use
for product acceptance.
6. In conjunction with evaluating Supplier QA program controls, the RE will determine
a Supplier’s 49CFR compliance capabilities for the production of drums. This
evaluation may take the form of Supplier facility visit/assessment, review of
document submittals, review of historical records or any combination thereof.
USA DOT 7A Type A Drums, xx-xxx-xxxx
Commercial Grade Item Procurement Revision 0a
Page 8 of 29
5.0 DRUM ACCEPTANCE
1. Subpart 2.14 Method 1 (M1) for CCs identified as required for acceptance from
Table 1 shall be implemented for each lot of delivered drums. M1 for other CCs may
be implemented for acceptance as required by the RE.
2. Development of M2 checklists and M3 plans shall include, as a minimum, the CCs
required for acceptance from Table 1 and applicable CPSA determinations from
Table 2 Column C. M2 and M3 criteria for other CCs may be included in checklists
or plans as required by the RE.
3. 7A Type A drums that are also marked as Non-bulk Performance Oriented
Specification Packaging (i.e., UN1A2/X/S) will require verification of correct
markings per 49 CFR 178.3 and 178.503.
6.0 TABLES - CONTENT DESCRIPTION
Table 1
Col A: Technical requirements.
Col B: CC for the corresponding technical requirements.
Col C: Indicates a CC that is mandatory for acceptance with each delivered lot of drums.
Col D: Method(s) used to accept the corresponding CC. The minimum details for
performing the acceptance activity are also included.
Col E: Details of supplier QA program and process implementation controls essential
for the corresponding CCs. These controls are to be assessed when executing
Col. C activities.
Table 2
Col A: Category of required Supplier QA program controls applicable to the production
of drums.
Col B: CPSA criteria for the corresponding QA program controls in Col. A.
Col C: Methods of evaluating and determining acceptance of the CPSA criteria. Details
are provided for supplier survey, surveillance, and document review activities.
Col D: Details of Supplier QA program and process implementation controls essential
for the corresponding CPSA criteria. These controls are to be assessed when
executing Col. C activities.
7.0 REFERENCES
1. ASME NQA-1-2008, Quality Assurance Requirements for Nuclear Facility
Applications/ASME NQA-1a-2009, Addenda to ASME NQA-1-2008
2. Title 49 CFR Chapter I, Subchapter C, Hazardous Materials Regulations
3. DOE Order 460.1 C, Packaging and Transportation Safety
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 9 of 29 Significant Rewrite, Change Bars Not Used
Design/Technical Requirements Basis
DTR-1:
49 CFR 178.350,
Specification 7A; general
packaging, Type A,
Paragraph (a)
Note: CCs to satisfy these
regulatory requirements
are captured under
multiple 49 CFR rows
below.
See below
See below
DTR-2:
49 CFR 173.412,
Additional Design
Requirements for Type A
packages
(1) Design includes
provisions for
installing a safety seal
such as a TID.
√
DRV Review/evaluation of drum drawing by RE.
Note: See DTR-7(4) for physical verifications.
(1) Development, issuance, and control
of fab/assembly documents.
(2) Materials specified for
use will perform
within prescribed
temperature range -
40oF to 158oF
DRV Review/evaluation of drum drawing by SRS
CTF.
M1 Review/evaluation of material certs during
receipt inspection.
(1) Development, issuance, and control
of fab/assembly documents.
(2) Material receipt verifications.
(3) Request, receipt, review/acceptance
of sub-tier supplier document.
(4) Processing and forwarding of
customer required document
submittals.
(3) Design includes a
containment system
that is securable by a
positive fastening
device
DRV Review/evaluation of drum drawing by SRS
CTF.
Note: See DTR-7(4) for physical verification of
positive fastening device components.
(1) Development, issuance, and control
of fab/assembly documents.
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 10 of 29 Significant Rewrite, Change Bars Not Used
DTR-2 cont. (4) Components/ materials
are suitable for content
radiolytic decomp. and
generation of gas
DRV Review/evaluation of drum drawing by RE
(based on knowledge of end/use and
contents).
(1) Development, issuance, and control
of fab/assembly documents.
Note: Supplier unaware of eventual
contents; responsibility will be to
use of steel types typical for drum
industry.
(5) Design provides for a
containment that
retains contents under
reduction of ambient
pressure to 3.6 psi. √* *If test
perf.
DRV Review/evaluation of drum drawing by SRS
CTF for presence of filter port (i.e., bung
fitting) if required by designA. If not, then
M2 or M3: Additional review /evaluation of
pressurization test by Supplier Test
Engineer and RE.
NoteA: Will also include verification by RE that
nuclear filter was included during design
performance testing or a 49 CFR 173.461
justification exists in lieu of physical testing.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
(6) Evaluation of design
against requirements
in 173.412 concludes
there would be no loss
or dispersal of rad
contents during use
DRV Review/evaluation of drum drawing and any
supplier provided design analysis by RE.
DRV Review/evaluation any test reports/analysis
by Supplier Test Engineer and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) Development, issuance, and control
of test procedures/reports or test
analysis.
DTR-3
49 CFR 173.410,
General design
requirements
(1) Design provides for
ease of handling and
securement on a
conveyance for
transport
DRV Review/evaluation of drum drawing by RE. (1) Development, issuance, and control
of fab/assembly documents.
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 11 of 29 Significant Rewrite, Change Bars Not Used
DTR-3 cont. (2) Design provides for an
external surface
relatively free from
protruding features
that is easily
decontaminated.
DRV Review/evaluation of drum drawing by RE. (1) Development, issuance, and control
of fab/assembly documents.
(3) Design provides for an
outer layer of
packaging that that is
relatively free of
pockets or crevices
that may collect water
DRV Review/evaluation of drum drawing by RE. (1) Development, issuance, and control
of fab/assembly documents.
(4) Design does not
include the addition of
features that will
reduce the safety of
the package
DRV Review/evaluation of drum drawing by RE.
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
(5) Design promotes
retention of contents
and integrity of
components and
fastening devices
during vibrations and
forces experienced
during normal
transport
DRV Review/evaluation of drum drawing by RE.
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 12 of 29 Significant Rewrite, Change Bars Not Used
DTR-3 cont. (6) Materials of
construction and
components or
structure are
chemically and
physically compatible
with contents
including affects of
packaging and
contents under
irradiation
DRV Review/evaluation of drum drawing by RE
(based on knowledge of intended
contents/use).
(1) Development, issuance, and control
of fab/assembly documents.
Note: Supplier unaware of eventual
contents; responsibility will be to
use of materials typical for drum
industry.
DTR-4:
49 CFR 173.24, General
requirements for
packagings and
packages.
(1) Design considers
effectiveness of
package during
transport for variables
such as temperatures,
changes in humidity &
pressure, shocks,
loading and vibration
DRV Review/evaluation of drum drawing by RE
(based on knowledge of intended
contents/use).
(1) Development, issuance, and control
of fab/assembly documents.
Note: Supplier unaware of eventual
contents; responsibility will be to
use of materials typical for drum
industry.
(2) Closures are leakproof
and securable against
loosening
DRV Review/evaluation of drum drawing by RE.
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 13 of 29 Significant Rewrite, Change Bars Not Used
DTR-4 cont. (3) Venting systems are so
designed as to prevent
unintentional release
of content
DRV Review/evaluation of drum drawing by RE.
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
DTR-5:
49 CFR 173.24a,
Additional general
requirements for non-
bulk packagings and
packages
(1) Nature and thickness
of designed materials
won’t generate a
sufficient amount of
heat during transport
to dangerously alter
the contents
DRV Review/evaluation of drum drawing by RE
(based on knowledge of intended
contents/use).
(1) Development, issuance, and control
of fab/assembly documents.
Note: Supplier unaware of eventual
contents; responsibility will be to
use of materials typical for drum
industry.
(2) Design is capable of
withstanding, without
rupture or leakage, the
vibration test
procedure in 178.608
DRV Review/evaluation of drum drawing by RE.
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 14 of 29 Significant Rewrite, Change Bars Not Used
DTR-6:
49 CFR 173.504,
Standards for steel drums
(1) Body and heads must
be constructed of sheet
steel, type and
thickness related to
capacity and use.
√
DRV Review/evaluation of drum drawing by RE
(based on knowledge of intended
contents/use).
DRV Review/evaluation of drum testing
report/analysis by Supplier Test Engineer
and RE.
M1 Review/evaluation of material certs during
receipt inspection.
M1 Verification of drum material thickness
markings during receipt inspection.
(1) Development, issuance, and control
of fab/assembly documents.
(2) If testing required, development,
issuance, and control of test
procedures/reports.
(3) Use of qualified test personnel.
(4) Execution of test activities.
(5) Development, issuance, and control
of fab/assembly documents.
(5) Material receipt verifications.
(6) Request, receipt, review/acceptance
of sub-tier supplier document.
(7) Processing and forwarding of
customer required document
submittals.
(2) Body seems are to be
mechanically seemed
or welded.
TBD TBD
(3) Chimes are to be
mechanically seamed
or welded.
TDB TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 15 of 29 Significant Rewrite, Change Bars Not Used
DTR-6 cont. (4) Body of a drum
greater than 16 gallons
may have at least 2
rolling hoops.
Separate rolling hoops
must be fitted tight
against the body
TBD TBD
(5) Closures for openings
in the bodies and heads
of drums and closure
devices are designed
such that they will
remain secure and
leakproof under
normal conditions of
transport.
TBD TBD
(6) Gaskets or other
sealing elements must
be used.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 16 of 29 Significant Rewrite, Change Bars Not Used
DTR-6 cont. (7) Body, heads, closures
and fittings must be
compatible with
intended contents or
suitably coated and
protected.
TBD TBD
(8) Maximum capacity of
the drum is 119
gallons
TBD TBD
(9) Maximum net mass of
the drum is 400 kg
(882 lbs.)
TBD TBD
DTR-7:
End-use Specifications
(1) Height and diameter
are as specified for
listed capacity.
TBD TBD
(2) Steel is the type
(carbon or stainless)
specified.
TBD TBD
(3) Body and head
thickness is 16
gage/1.35 (minimum).
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 17 of 29 Significant Rewrite, Change Bars Not Used
DTR-7 cont. (4) Closure ring is the type
specified (e.g., bolted,
lever lock, etc.).
Bolted rings jam nut
and bolts with TID
hole.
TBD TBD
(5) Closure ring lug welds
are sufficiently sized
and located for applied
loads.
TBD TBD
(6) Lid includes the
specified number of
¾” or 2” bung fittings
required for an order.
Bung fitting is a
manufactured type that
will accommodate
NPSC or NPSM filter
threads.
TBD TBD
(7) Gasket is EPDM type
and securely glued to
lid.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 18 of 29 Significant Rewrite, Change Bars Not Used
DTR-7 cont. (8) Exterior coating is tan
in color.
Exterior/interior DFT
is 0.8 mil minimum.
TBD TBD
(9) 7A Type A markings
are applied per 49 CFR
178.350. UN
Markings are applied
per 49 CFR 178.503
for a UN 1A2/X4xx/S
drum. Markings are a
minimum of ½” high
per 49 CFR 172.310.
Sides of drums are
marked with gross
mass.
TBD TBD
(10) Testing was
performed to qualify
drums for the specified
material forms.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 19 of 29 Significant Rewrite, Change Bars Not Used
Design/Performance Testing
DPT-1
49 CFR 173.412,
Additional design
requirements for Type A
packages, Paragraph (j)
Evaluation of tests or
alternate methods for
testing demonstrates no
loss or dispersal of the
radioactive contents
TBD TBD
DPT-2
49 CFR 173.461,
Demonstration of
compliance with tests
(1) Compliance with
173.412 design
requirements and
173.465 testing
requirements is by one
or a combination of
the methods prescribed
in 173.461
TBD TBD
(2)Initial conditions for
173.465 - .469 tests
(except for water
immersion)
compliance was based
on the assumption that
package is in
equilibrium at ambient
temp. of 100o F
. TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 20 of 29 Significant Rewrite, Change Bars Not Used
DPT-3
49 CFR 173.462,
Preparation of specimens
for testing
(1) Test specimen is
examined prior to
testing to identify and
record faults or
damage, including:
-Divergence from spec
or drawings
-Defects in
construction
-Corrosion or other
deterioration
-Distortion of features
TBD TBD
(2) Deviations from
design found during
examination corrected
prior to test or taken
into account when
evaluating test results
TBD TBD
(3) Containment system of
the packaging to be
tested is clearly
defined
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 21 of 29 Significant Rewrite, Change Bars Not Used
DPT-3 cont. (4) External features of
the test specimen are
clearly identified (for
purpose of referencing
during test)
TBD TBD
DPT-4
49 CFR 173.465, Type A
packaging tests
(1) Specimen(s) is
subjected to the water
spray test or
compliance is justified
through 173.461(a)
Other Methods as a
preceding to other
173.465 tests. As a
result of this test, (a)
there is no loss or
dispersal of content
and (b) there is not a
significant increase in
the radiation levels
recorded or calculated
at the external surfaces
for the condition
before the test.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 22 of 29 Significant Rewrite, Change Bars Not Used
DPT-4 cont. (2) Specimen(s) is
subjected to the free
drop, stacking, and
penetration test or
compliance is justified
through 173.461(a)
Other Methods and
results in (a) no loss or
dispersal of content
and (b) there is not a
significant increase in
the radiation levels
recorded or calculated
at the external surfaces
for the condition
before the test.
TBD TBD
DPT-5
49 CFR 178.608,
Vibration standard
Specimen(s) are subjected
to the vibration test or
justified as capable of
passing the test.
Acceptance after test is no
rupture, leakage,
deterioration that could
adversely affect
transportation safety.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 23 of 29 Significant Rewrite, Change Bars Not Used
Fabrication Activities
FA-1
Material Preparation
Aligns with Design
(1) Materials pulled from
inventory/storage are
correct for the design
and useable (i.e.,
checked for
damage/defects).
TBD TBD
(2) Materials are cut, bent,
formed, and cleaned per
design and procedural
requirements.
TBD TBD
FA-2
Component/Parts
Assembly Aligns with
Design
(1) All parts & components
are configured and
positioned per design
requirements.
TBD TBD
(2) Method and process of
connecting/joining
drum body and heads
are per design.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 24 of 29 Significant Rewrite, Change Bars Not Used
FA-2 cont. (3) Lug welding to closure
ring is per design and
associated sub-
supplier weld
procedures.
TBD TBD TBD
(4) When included in
design, bung fitting(s)
are present, sized,
located and press fit in
lid correctly.
TBD TBD TBD
FA-3
Applied Coatings (when
applicable) Align with
Design
(1) Coating system
selected meets SRS
specifications and is
compatible with base
materials.
TBD TBD TBD
(2) Surface preparation is
in accordance with
coatings manufacturer
recommended
practices and/or SRS
specifications.
TBD TBD TBD
(3) Coatings applied in
accordance with
manufacturer
recommended
practices and/or SRS
specs.
TBD TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 25 of 29 Significant Rewrite, Change Bars Not Used
FA-4
Production Testing is in
Accordance with
Established Procedures
(1) All items (or sample if
applicable) are
subjected to tests.
TBD TBD
(2) Item is prepared for
test in accordance with
test procedure.
TBD TBD
(3) Test is performed in
accordance with
prescribed procedure.
TBD TBD
(4) Items successfully
tested or
reworked/retested or
scrapped.
TBD TBD
FA-5
Final Assembly is in
Accordance with Design
and Preparation for
Shipment is per
Procedure/Contract
(1) All fabrication,
assembly, testing, and
in-process inspections
are complete.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Technical Requirements
(Design, performance,
testing, fabrication, and
assembly)
B.
Critical Characteristics
(CCs)
C.
CCs
Req’d
for
Accept.
√
D.
Methods of Acceptance
M1 – Sbprt 2.14 Method 1
M2 – Sbprt 2.14 Method 2
M3 – Sbprt 2.14 Method 3
DRV – Document Review
Verification
E.
Supplier Document, Receipt, Production
and Product Verification Controls
Page 26 of 29 Significant Rewrite, Change Bars Not Used
FA-5 cont. (2) Completed item meets
all design and
specification
requirements.
TBD TBD
(3) Required markings
applied.
TBD TBD
(4) Packaging, including
loose material/
components, is
properly prepared and
ready for shipment.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Requirements Applicable to
Production & Supply
B.
CPSA
C.
Methods of Acceptance
D.
Supplier QA Program and Process Implementation
Controls
Page 27 of 29 Significant Rewrite, Change Bars Not Used
FA-6
Documents issued for
production
Only approved design,
work control, testing, and
inspection documents are
issued and used during
production.
TBD TBD
FA-7
Material Ordering Aligns
with Design
(1) Materials ordered are
derived from design
documents and are of a
correct type, size, and
part/model number if a
commercial item.
TBD TBD
(2) Materials are acquired
from sub-suppliers
appropriately qualified
for the type and nature
of the product supplied.
TBD TBD
FA-8
49 CFR 173.474, Quality
control for construction
of packaging.
The packaging (container)
meets the quality of design
and construction
requirements of the HMR
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Requirements Applicable to
Production & Supply
B.
CPSA
C.
Methods of Acceptance
D.
Supplier QA Program and Process Implementation
Controls
Page 28 of 29 Significant Rewrite, Change Bars Not Used
Documentation
D-1
49 CFR 173.415(a),
Authorized Type A
packages
The following 7A Type A
documents were generated
and are available:
Type A test
documentation
Design drawing
Eng. evaluations/
comparative data
showing design and
materials of
construction comply
with 7A Type A
specification`
TBD TBD
D-2
49 CFR 178.2(c),
Notification
Closure instructions were
generated and are available
for the effective assembly
and closure of the
packaging to prevent
leakage during transport.
TBD TBD
D-3
SRS Specified
Documents in Addition
to 49 CFR Submittals
Documents required were
submitted and provide
evidence of a satisfactory
product.
TBD TBD
USA DOT 7A Type A Drums, Commercial Grade Item Procurement G-TRT-G-00022
TABLE 1 Revision 2a A.
Requirements Applicable to
Production & Supply
B.
CPSA
C.
Methods of Acceptance
D.
Supplier QA Program and Process Implementation
Controls
Page 29 of 29 Significant Rewrite, Change Bars Not Used
Personnel Qualifications
PQ-1
49 CFR 171.8 Hazmat
Employee (definition);
49 CFR Part 172,
Subpart H – Training
Personnel involved in the
design, manufacturing,
fabrication, inspection,
marking, or testing of a
packaging is properly
trained to requirements in
Subpart H as a Hazmat
Employee
TBD TBD
PQ-2
SRS Specified
Inspection and Test
Personnel Qualification
Requirements
Inspection and Test
personnel meet the
qualification requirements
of ASME NQA-1, Part 1,
Rqmt. 2 para. 302.
TBD TBD
PQ-3
SRS Specified General
Employee Training/
Qualification Reqmnts.
Employees performing
work on SRS designated
items are to be trained and
qualified for their activities
TBD TBD