USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0084 ([RWE NUKEM Corporation] [Mr. Stan Hodges])

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

Interpretation Response Details

Response Publish Date:

Company Name: RWE NUKEM Corporation

Individual Name: Mr. Stan Hodges

Location State: SC Country: US

View the Interpretation Document

Response text:

Jun 7, 2006


Mr. Stan Hodges                Reference No. 06-0084
RWE NUKEM Corporation
3800 Fernandina Road
Suite 200
Columbia, SC 29210

Dear Mr. Hodges:

This responds to your letter concerning the use of freight containers as Industrial packages Types 2 or 3 (Type IP-2) or (Type IP-3) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. Paragraph 627 of the International Atomic Energy Agency s (IAEA) Regulations for the Safe Transport of Radioactive Material (TS-R-1) authorizes the use of freight containers as Industrial packages Types 2 or 3 (Type IP-2) or (Type IP-3) provided they are designed to conform to the standards prescribed in the International Organization for Standardization’s (ISO) standard ISO 1496-1. Paragraph 627 also requires freight containers to be designed such that if subjected to the tests prescribed in ISO 1496-land the accelerations occurring during routine conditions of transport they would prevent:

(a) loss or dispersal of the radioactive contents; and
(b) loss of shielding integrity which would result in more than a 20% increase in
the radiation level at any internal surface of the freight container.

What type of calculation would be needed to prove the requirements have been met?

Al. Any of the methods described in paragraphs 701 and 702 of IAEA’s TS-R-1 (incorporated by reference in § 171.7) may be used to demonstrate compliance with the test standards. Paragraph 701 describes methods to demonstrate compliance with the performance standards and paragraph 702 requires appropriate methods of assessment of the test results to ensure compliance with the performance and acceptance standards. Compliance with the test standards may be accomplished by any one of the following methods:

(1) Performance of tests with specimens representing LS.A-III material, or special form radioactive material, or low dispersible radioactive material or with prototypes or samples of the packaging, where the contents of the specimen or the packaging for the tests shall simulate as closely as practicable the expected range of radioactive contents and the specimen or packaging to be tested shall be prepared as presented for transport.

 (2) Reference to previous satisfactory demonstrations of a sufficiently similar nature.

(3) Performance of tests with models of appropriate scale incorporating those features which are significant with respect to the item under investigation when engineering experience has shown results of those tests to be suitable for design purposes. When a scale model is used, the need for adjusting certain test parameters, such as the penetrator diameter or the compressive load, shall be taken into account.

(4) Calculation, or reasoned argument, when the calculation procedures and parameters are generally agreed to be reliable or conservative.

Q2. May closed packages be placed inside a freight container if the packages are properly blocked and braced to prevent movement relative to the accelerations occurring during routine conditions of transport?

A2. The answer is yes, provided the shipper, using any of the methods described in paragraphs 701 and 702 of TS-R-1, can demonstrate that the conditions in paragraph 627 of TS-R-l have been satisfied.

Q3. If a freight container is equipped with passive vents, are the passive vents required to be blanked off and HEPA filters installed when closed containers of radioactive materials are transported in the freight container?

A3. The answer is no, provided the freight container and its radioactive contents have successfully met the IAEA TS-R-l paragraph 627 test requirements.

I trust this satisfies your inquiry.



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


Regulation Sections

Section Subject
173.403 Definitions