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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

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.24a Additional general requirements for non-bulk packagings and packages
173.24b Additional general requirements for bulk packagings
173.412 Additional design requirements for Type A packages