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Interpretation Response #05-0082


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

Interpretation Response Details

Response Publish Date: 04-14-2005
Company Name: United States Regulatory Commission    Individual Name: Mr. David Pstrak
Location state: DC    Country: US

View the Interpretation Document


Response text:

Apr 14, 2005

 

Mr. David Pstrak                      Reference No. 05-0082
Nuclear Material Safety and Safeguards
Spent Fuel Project Office - 13D13
United States I’ Regulatory Commission
Washington, D.C. 20555-0001

Dear Mr. Pstrak:

This responds to your letter of April 7, 2005, requesting clarification as to whether a shipper that has drilled holes in a “Type A package” must perform an analysis on the package to confirm that no contents would be released.

The answer is yes. It is the opinion of this office that if holes are drilled in a package that was previously demonstrated to satisfy the “Type A package” performance requirements, the package would no longer be identical to the previously designed and tested package. Therefore, a “Type A package” that has holes drilled in it, may not continue to be designated as a “Type A package” until it has been completely evaluated against the specifications specified in § 178.350. That evaluation may be conducted using any of the methods described in § 173.461(a), or a combination of them, and documented in accordance with § 173.415(a).

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,

 

Susan Gorsky
Acting Director, Office of Hazardous
   Materials Standards

173.416


Regulation Sections

Section Subject
§ 173.416 Authorized Type B packages