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Interpretation Response #10-0103 ([Calfrac Well Services Corp.] [Mr. Dave Mykyte])

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

Interpretation Response Details

Response Publish Date:

Company Name: Calfrac Well Services Corp.

Individual Name: Mr. Dave Mykyte

Location State: AR Country: US

View the Interpretation Document

Response text:

May 26, 2010

 

 

 

 

Mr. Dave Mykyte

Calfrac Well Services Corp.

164 - Hwy 64

Beebe, Arkansas 72012



Ref. No. 10-0103

Dear Mr. Mykyte:

This responds to your April 28, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide a description and pictures of a Class 7 (radioactive) material in a Type A package, which you refer to as a blender densitometer. The Type A package is attached to the frame of a machine mounted on a trailer. A steel sleeve that fits over the package is bolted in place using existing bolt holes on the frame of the Type A package to provide additional shielding. Specifically, you ask if the steel sleeve meets the definition of an overpack in the HMR.

The answer is no. An overpack is defined in § 171.8 to mean an enclosure used by a single consignor to provide protection or convenience in the handling of a package or to consolidate two or more packages. An example of an overpack is one or more packages placed in a protective outer packaging such as a box or crate. The steel sleeve semi-permanently attached to the Type A package is considered an attachment to the Type A package; therefore, it does not meet the definition of an overpack.

I hope this information is helpful. If you have further questions, please contact this office.

Sincerely,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.8

Regulation Sections