Interpretation Response #03-0013 ([Bechtel Hanford, Inc.] [Mr. J. M. Atwood])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Bechtel Hanford, Inc.
Individual Name: Mr. J. M. Atwood
Location State: WA Country: US
View the Interpretation Document
Response text:
Feb 14, 2003
Mr. J. M. Atwood Reference No. 03-0013
Manager, Waste Management/Transportation
Bechtel Hanford, Inc.
3350 George Washington Way
Richland, WA 99352
Dear. Mr. Atwood:
This is in response to your letter dated January 13, 2003 requesting a clarification of the packaging requirements for Uranium metal, pyrophoric, UN2979, under the Hazardous Materials Regulations (49 CFR Parts 171-180). Specifically, you ask what test criteria must the packaging configuration meet.
Section 173.418 requires pyrophoric Class 7 (radioactive) materials in quantities not exceeding A2 Per package to be transported in DOT Specification 7A packagings constructed of materials that will not react with, nor be decomposed by, the contents. In addition, the contents of the package must among other things be inerted to prevent self-ignition during transport by either:
(1) Mixing with large volumes of inerting materials, such as graphite, dry sand, or other suitable inerting material, or blended into a matrix of hardened concrete; or
(2) Filling the innermost receptacle with an appropriate inert gas or liquid.
In your letter, you stated that your depleted uranium is packaged in small drums (nominally 30 gallons) filled with mineral oil as a liquid inerting agent. You further stated that, the small drum is then placed inside a larger (nominally 55 gallons) DOT Specification 7A package. Therefore, your DOT Specification 7A package must conform to the Type A packaging tests prescribed in §§ 173.465 and 173.466.
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.418