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Interpretation Response #08-0245 ([Department of Energy] [Mr. James M. Shuler])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of Energy

Individual Name: Mr. James M. Shuler

Location State: DC Country: US

View the Interpretation Document

Response text:

November 26, 2008




Mr. James M. Shuler

Manager, Packaging Certification Program

Safety Management and Operations

Office of Environmental Management

Department of Energy

Washington, DC 20585

Ref. No. 08-0245

Dear Mr. Shuler:

This responds to your September 29, 2008 letter requesting clarification of Competent Authority approvals USA/0696/S-96 and USA/0695/S-96 issued by the U.S. Department of Transportation in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the competent authority approvals referenced above, are required to specifically list daughter products, which would be present during transportation. If so, you ask if it would be necessary to apply for a modification to the above mentioned approvals to specifically list the additional radionuclides in order for those Competent Authority approvals to be valid.

The answer is no. Competent Authority approvals issued in accordance with § 173.476 of the HMR require a detailed description of the contents of a special form capsule. However, the approvals do not have to identify daughter products that are part of the natural decay chain of the parent radionuclide. Therefore, it is not necessary to apply for a modification of the above referenced competent authority approvals to identify daughter products.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

Charles Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.476

Regulation Sections

Section Subject
173.433 Requirements for determining basic radionuclide values, and for the listing of radionuclides on shipping papers and labels
173.476 Approval of special form Class 7 (radioactive) materials