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Interpretation Response #05-0094 ([MHF Logistical Solutions] [Mr. Kurt Colborn])

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

Interpretation Response Details

Response Publish Date:

Company Name: MHF Logistical Solutions

Individual Name: Mr. Kurt Colborn

Location State: PA Country: US

View the Interpretation Document

Response text:

Jun 14, 2005

Mr. Kurt Colborn                      Reference No. 05-0094
Director, Technical Services
MHF Logistical Solutions
800 Cranberry Woods Drive, Suite 450
Cranberry Township, PA 16066

Dear Mr. Colborn:

This responds to your April 18, 2005, letter requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Class 7 Radioactive
Materials (RAM). Your questions are paraphrased and answered below:

Q1.      You ask whether the definition for “contamination” represents a limit on the combined total fixed and non-fixed radioactive contamination.

Al.        The answer is yes. As defined in § 173.403, contamination is the presence of radioactive substance on a surface in quantities in excess of 0.4 Bq/cm² for beta and gamma emitters and low toxicity alpha emitters or 0.4 Bq/cm² for all other alpha emitters. Contamination exists in two phases.

Q2.      You ask whether a default wiping efficiency of 0.10, or the actual wipe efficiency, may be used to convert the measurements to surface contamination levels when measuring non-fixed (removable) contamination transferred to a wipe.

A2.      The answer is yes. As specified in § 173.443(a)(l), a default wiping efficiency of 0.10, or the actual wipe efficiency, maybe used to determine the level of non.- fixed radioactive contamination.

Q3.      You ask whether the definition for “contamination” represents the lower limit of contamination, below which objects and empty containers are not subject to the radioactive material transport requirements of the HMR, provided radioactive contents are below at least one of the exemption values in the table found in § 173.436 or calculated by methods described in § 173.433.

A3.      The answer is yes. A non-radioactive object or empty non-radioactive container with radioactive contamination below the definition of “contamination” in § 173.403 are not subject to the radioactive material transport requirements of the HMR.

Q4.      You ask whether the definition for “contamination” represents the lower limit on contamination, above which contaminated items must be transported, at a minimum, as Surface Contaminated Objects (SCO).

A4.      The answer is yes. A non-radioactive object with an actual radioactive contamination equal to or greater than the definition of “radioactive material” as defined in § 173.403 must be regulated as a Class 7 (Radioactive) hazardous material.

Q5.      You ask whether the definition for “contamination” represents a lower limit of contamination for packagings that previously contained Class 7 radioactive materials and have been sufficiently cleaned in a manner that exempts them from marking and labeling requirements as specified in § 173.428.

A5.      The lower limit of the definition for “contamination” applies to packagings that previously contained Class 7 radioactive materials provided the packaging contains no volume radioactivity, any contamination on the inner surfaces is below the definition for “contamination” as specified in § 17:3.40.3, and all labels and markings associated with its use as a RAM packaging are removed.

Q6.You ask whether empty containers that are contaminated above the limit specified in § 173.403 must be transported in accordance with § 173 .428.

A6.      The answer is yes. Empty containers that are contaminated above the limit specified in § 173.403 must be transported in accordance with § 173.428 when the conditions cited in § 173.428 are met, even if the contamination is on the outside of the container. If the conditions of § 173.428 cannot be met, such a container must be shipped in accordance with the appropriate requirements for transporting Class 7 (radioactive) material.

Q7.      You ask whether the upper limit of permissible contamination on exposed surfaces of an empty packaging is determined in accordance with § 173.443.

A7.      Provided the empty packaging is transported in accordance with § 173.428, the upper limit of permissible contamination on exposed surfaces of an empty packaging is determined in accordance with § 173.443.

Q8.      You ask, when shipping a package of radioactive material, whether the contamination, limits in § 173.443 apply, and whether the transportation requirements based on package contents take precedence over the definition of “contamination” found in § 173.403. You also ask whether such a package can be transported without additional and potentially conflicting markings for SCO.

A8.      The answer is yes. A package of Class 7 (radioactive) material may have exterior surface contamination up to the limits cited in §173.443, which are higher than the numbers listed in the definition of “contamination” in § 173.403. 

As defined in § 173.403, a Surface Contaminated Object (SCO) is a solid object which is not itself radioactive, but which has radioactive material distributed on its surface. Thus, any material which is defined as “radioactive material” as specified in § 173.403, or any package containing such radioactive mat cannot also be an SCO even if it has radioactive material on its surface.

I hope this information is helpful.

Sincerely,

 

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.403, 173.443

Regulation Sections

Section Subject
173.403 Definitions
173.443 Contamination control