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Interpretation Response #02-0116 ([Science Applications International Corporation] [James R. Price])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Science Applications International Corporation

Individual Name: James R. Price

Location State: CA Country: US

View the Interpretation Document

Response text:

June 4, 2002

Mr. James R. Price                                         Reference  No. 02-0116     
Senior Environmental Compliance
& Health and Safety Officer
Science Applications International Corporation
10260 Campus Point Drive
M/S B2-M
San Diego, CA 92121

Dear Mr. Price:

This is in response to your letter requesting clarification of the shipping paper and contamination control requirements for radioactive materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your company operates Mobile Vehicle and Cargo Inspection Systems (VACIS) to inspect the contents of trucks, containers, cargo and passenger vehicles for explosive devices and/or contraband.  Each Mobile VACIS is equipped with a semi-permanently mounted gauge device (Type A package) containing either a 59 Gbq Cesium-137 or 37 Gbq Cobalt-60 radioactive material sealed source.

Your questions are paraphrased and answered as follows:

Ql. Science Applications International Corporation (SAIC) prepares a shipping paper when the Mobile VACIS first enters a public highway.  Can the same shipping paper remain with the vehicle for its lifetime or until the Type A package is reshipped or transferred to another vehicle?

Al. The answer is yes.  The same shipping paper may remain with the Mobile VACUOUS for its lifetime provided the content (including quantity) of the Type A package remains the same or the Type A package is reshaped or transferred to another vehicle.

Q2. Section 173.443 (a) requires a determination of the level of non-fixed radioactive contamination.  SAID interprets this to mean that a wipe survey must be performed prior to putting the vehicle into service on a public highway.  SAID would perform subsequent wipe surveys in accordance with the requirements of its Device Registry which requires leak testing prior to initial use and at intervals not to exceed 12 months.  The techniques used would be capable of detecting 185 Be of removable contamination.  Additional contamination surveys would not be required each time the truck is driven on a public highway.  Would our procedures satisfy the requirements of the HER?

A2. Section 173.443(a) requires the level of non-fixed (removable) radioactive contamination on the external surfaces of a package offered for transportation to be kept as low as reasonably achievable.  The HER require that the non-fixed radiation contamination not exceed the limits set forth in Table 11 and authorize the use of a wipe survey or other assessment method to check for non-fixed radioactive contamination.  The HER do not prescribe surveys at scheduled intervals.  However, the shipper should have an assessment methodology in place to ensure compliance whenever the material is in transport.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Hattie L. Mitchell
Chief, Regulatory Review and Reinfection
Office of  Hazardous Materials Standards


Regulation Sections

Section Subject
173.443 Contamination control