Interpretation Response #06-0189 ([Nukem Corporation] [Mr. Stan Hodges])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Nukem Corporation
Individual Name: Mr. Stan Hodges
Location State: SC Country: US
View the Interpretation Document
Response text:
Sep 29, 2006
Mr. Stan Hodges Reference No. 06-0189
Senior Project Manager
Nukem Corporation
3800 Fernandina Road Suite 200
Columbia, SC 29210
Dear Mr. Hodges:
This is in response to your August 15, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to HEPA vents. Your question pertains to § 173.412(f) which requires the containment system to retain its radioactive contents under the reduction of ambient pressure to 25 kPa (3.6 psi). Specifically, you ask if a passive HEPA vent may be installed in a Type A package to meet the pressure requirement in § 173.412(f) as long as the resultant containment system would not release any radioactivity to the environment.
The HMR do not prohibit the use of vents in Type A packagings containing Class 7 (radioactive) materials. However, the packaging must be an authorized packaging for the Class 7 (radioactive) material under the HMR, meet the HMR design specification (if applicable), and comply with the general packaging requirements in Part 173, Subpart B. The Type A packaging, with the vent, must meet the design and construction requirements in § 178.350, which also requires compliance with § 173.403, 173.410, 173.412, 173.415, 173.465 and 173.466.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.412(f)
Regulation Sections
| Section | Subject |
|---|---|
| 173.412 | Additional design requirements for Type A packages |