Interpretation Response #06-0201
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Nov 2, 2006
Mr. Mark B. Hawk Reference No. 06-0201
Nuclear Science & Technology Division
Oak Ridge National Laboratory
P.O. Box 2008
OakRidge, TN 37831
Dear Mr. Hawk:
This is in response to your letter concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for steel boxes and other types of radioactive material packagings used for the transport of low-level radioactive materials.
The requirements for steel boxes designed and fabricated to be used as IP-1, IP-2, or IP-3 and Type A packaging are contained in § 173.24, 173.24a, 173.410, 173.411 and 173.412, respectively. You ask several questions regarding these requirements. Your questions are paraphrased and answered as follows:
Q1. What design elements of Class 7 (radioactive) packagings constitute a new or different design such that testing and engineering evaluations are required to prove conformance with the applicable design requirements of § 173.4 10, 173.411, and 173.412?
Al A package that differs from a previously qualified design type in structural design, size material of construction, wall thickness, or manner of construction is subject to engineering evaluations and testing in the same manner as the original packaging. A change in the package contents (i.e., activity amount, form of material, etc.) that differs from that previously qualified would also be subject to the same package content evaluations and testing as the original. Regarding demonstration of compliance, packages for radioactive materials must comply with the requirements in § 173.46 1.
Q2. What vibration test should be used to ensure a package complies with the requirements in § 173.410(f)? Is there a different vibration standard for bulk and non-bulk packages?
A2. Section 173.410(f) states that a package must be capable of withstanding ‘the effects of acceleration, vibration, or vibration resonance that occur under normal
conditions of transportation without any reduction in the effectiveness of the package. The section does not prescribe a specific standard to which bulk or non- bulk packages must conform. It is the responsibility of the shipper to ensure that any package constructed in accordance with § 173.410 maintains its integrity under normal conditions of transportation and repeated use. In addition, all non-bulk packages are subject to the general packaging requirements in § 173.24a and in accordance with paragraph (a)(5) must be capable of withstanding, without rupture or leakage, the vibration test in § 178.608.
Q3. Section 173.410(f) refers to general package and packaging requirements contained in § 173.24 and general non-bulk and bulk package and packaging requirements in § 173.24a and 173.24b, respectively. Are the terms “bulk,” “non-bulk,” and “IBC” applicable to Class 7 packages and packagings? If these terms dc apply, are all of the requirements throughout the HMR (i.e., marking) for each term applicable?
A3. The terms “bulk” and “non-bulk” are applicable to packagings used for the transportation of Class 7 materials. However, the packaging and hazard communication requirements specific to shipments of Class 7 materials supersede the packaging and hazard communication requirements that apply to other classes of hazardous materials. See, for example, the specific marking requirements for packages of Class 7 materials in § 172.3 10 and labeling requirements for packages of Class 7 materials in § 172.403.
I hope this information is helpful. Please contact us if you require additional assistance.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 173.461||Demonstration of compliance with tests|