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Interpretation Response #07-0089 ([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:

May 16, 2007

 

Mr. Spencer B. Neyland                 Reference No. 07-0089
Operations Manager/Physicist
LND, Inc.
3230 Lawson Boulevard
Oceanside, NY 11572

Dear Mr. Neyland:

This responds to your April 23, 2007 letter requesting further clarification of the packaging requirements for certain hermetically sealed nuclear radiation sensor (detector) tubes containing less than one gram of Boron trifluoride, 2.3, Hazard Zone B, at less than atmospheric pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

In our April 18, 2007 response, we informed you that based on the form and quantity of Boron trifluoride contained in the radiation detector tubes, it is our determination the tubes, when packaged in a specially designed packaging 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. You ask whether our reference to specifically designed packaging refers to the outside packaging described in Special Permit 12087 or the polyethylene ball that is a part of the power supply/meter described in your January 15, 2007 letter. The use of either packaging is acceptable for shipment of the radiation detector tubes.

I trust this satisfies your inquiry.

Sincerely,

 

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous materials Safety

172.101, 173.22 (a)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility