Interpretation Response #06-0241 ([LND, Inc.] [Mr. Spencer B. Neyland])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: LND, Inc.
Individual Name: Mr. Spencer B. Neyland
Location State: NY Country: US
View the Interpretation Document
Response text:
Apr 18, 2007
Mr. Spencer B. Neyland Reference No. 06-0241
Operations Manager/Physicist
LND, Inc.
3230 Lawson Boulevard
Oceanside, NY 11572
Dear Mr. Neyland:
This responds to your October 24, 2006 letter concerning the transportation of several styles of hermetically sealed nuclear radiation sensor (detector) tubes containing various quantities of Boron trifluoride, 2.3, Hazard Zone B, at less than atmospheric pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Subsequently, you submitted additional information and samples for our review.
According to your letter, LND, Inc. is the holder of Special Permit 12087, which authorizes the manufacture, mark, sale and use of nonrefillable, non-DOT specification cylinders with not more than 57 grams of Boron, trifluoride for transportation in commerce. You enclosed a letter of interpretation (Crawford; February 9, 1984) which informed the writer that “due to the form and limited quantity of boron trifluoride contained in the radiation detector tubes,” these devices are not subject to the HMR. The response was in reference to a question concerning the transportation of radiation detector tubes, each containing less than one gram of Boron trifluoride at less than atmospheric pressure. You asked if this exception also applies to certain LND nuclear radiation detector tubes containing less than one gram of Boron trifluoride at less than atmospheric pressure, and if this exception applies to international shipments and air shipments made under the International Civil Organization’s (ICAO) Technical Instructions.
We reviewed the additional information submitted on the hermetically sealed detector tubes, each containing not more than one gram of Boron trifluoride filled to less than atmospheric pressure, and packaged in a specially designed packaging. Based on the form and quantity of Boron trifluoride contained in the radiation detector tubes, it is our
determination these tubes, when packaged and offered for shipment as described in your letter, will not pose an unreasonable risk to health, public safety or property during transportation and, therefore, are not subject to the HMR.
We apologize for the delay in responding. Your confidential additional information and samples are herewith returned.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Safety
Enclosures
172.101, 173.4