Interpretation Response #13-0198 ([Hazwaste Packaging Consultants] [Mr. Robert White])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazwaste Packaging Consultants
Individual Name: Mr. Robert White
Location State: TN Country: US
View the Interpretation Document
Response text:
February 20, 2014
Mr. Robert White
Owner/CEO
Hazwaste Packaging Consultants
PO Box 209
Lenoir City, TN 37771-0209
Reference No. 13-0198
Dear Mr. White:
This is in response to your September 19, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging. Your questions are paraphrased and answered below:
Q1: You state that in the absence of a reduced atmospheric pressure chamber, you internally pressurize a Type A packaging containing a radioactive material to 11.1 pounds per square inch (psi), close the air supply, and monitor the pressure gauge for a period of 5 minutes. You ask if the packaging is considered to have met the requirements in
§ 173.412(f) for reduction of ambient pressure if there is no loss in pressure for the 5 minute period.
A1: The requirement in § 173.412(f) for demonstrating whether a package can withstand reduction of ambient pressure to 25 kPa (3.6 psi) is a design capability requirement. As required by § 173.412(f), the containment system must retain its radioactive contents under the reduction of ambient pressure to 25kPa (3.6 psi).
Q2: You state that § 173.410(f) references §§ 173.24, 173.24a, and 173.24b. You ask if §§ 173.24, 173.24a, and 173.24b all apply to both bulk and non-bulk packages.
A2: Non-bulk packages would be subject to the packaging requirements in §§ 173.24 and 173.24a; bulk packages would be subject to the requirements of §§ 173.24 and 173.24b.
Q3: You state that the packaging that is most commonly tested for Department of Energy (DOE) sites is a 96 cubic foot container filled to a gross weight of 11,000 pounds. You further state that the packaging can be designed and tested as an IP-1, IP-2, IP-2, 7A Type A, or 7A Type A, Fissile Qualified. You ask whether a 96 cubic foot container would be considered a bulk packaging. Additionally, you ask if this packaging is considered a non-bulk package, would it be permissible to test a single package to meet the vibration test as required by § 178.608.
A3: PHMSA defines a bulk packaging in § 171.8 as having a net mass greater than 400 kg (882 pounds). Since your packaging has a gross weight of 11,000 pounds it would be considered a bulk packaging under the HMR. A vibration test for a bulk packaging is not required under § 178.608.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.412, 173.24, 173.24a, 173.24b