Interpretation Response #02-0117 ([United States Enrichment Corporation] [M.Elizabeth Darrough, Ph.D])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: United States Enrichment Corporation
Individual Name: M.Elizabeth Darrough, Ph.D
Location State: MD Country: US
View the Interpretation Document
Response text:
June 13, 2002
M. Elizabeth Darrough, Ph.D Reference No. 02-0117
Director, Transportation Programs
United States Enrichment Corporation
6903 Rockledge Drive
Bethesda, MD 20817-1818
Dear Dr. Darrough:
This is in response to your letter dated April 18, 2002, requesting clarification regarding the requirements for marking your uranium hexafluoride cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Section 173.420 of the HMR provides that uranium hexafluoride packagings must be designed, fabricated, inspected, tested and marked in accordance with the American National Standards Institute (ANSI) N14.1 (1990, 1987, 1982, 1971) in effect at the time the packaging was manufactured. Section 6.10.7 of ANSI N14.1-1990 states that the 30B cylinder's nameplate shall be marked in characters a minimum of 5/16", high as described in Figure 13(b). However, Figure 13(b) shows typical characters as 5/32" high and states that the dimensions shown can be varied to provide the information required. Similar inconsistencies exist for the 48-inch cylinders, in sections 6.11.7, 6.12.7 and 6.13.7 of ANSI N14.1, which reference Figures 13(c) and 13(d). Specifically, you ask whether, the cylinders can be marked in accordance with the referenced figures, rather than the minimum heights referenced in the text sections of ANSI N14.1-1990.
From the information provided, it is our opinion that cylinders marked in conformance with the referenced figures would satisfy the requirements in the ANSI N14.1 standard. Also, as you stated in your letter, it is our understanding that the 2001 version of ANSI N14.1 will correct these inconsistencies by revising the text sections io agree with the figures.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.420