Interpretation Response #14-0120 ([RADIAC Program Operations] [Mr. Melvin J. Simon])

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

Interpretation Response Details

Response Publish Date: 07/15/2014

Company Name: RADIAC Program Operations

Individual Name: Mr. Melvin J. Simon

Location State: DC Country: US

View the Interpretation Document

Response text:

July 15, 2014

Mr. Melvin J. Simon
NAVSEA 04ND3
RADIAC Program Operations
Acting Technical Warrant Holder
Naval Sea Systems Command
1333 Isaac Hull Avenue, SE Stop 4120
Washington Navy Yard, DC  20376-4120

Ref. No.: 14-0120

Dear Mr. Simon:

This is in response to your email dated June 16, 2014, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the transportation of neutron radiation detectors containing boron trifluoride.  Section 172.102(c)(1) Special Provision 238 paragraph (c) offers relief from the other requirements of the HMR for neutron radiation detectors containing not more than 1 gram of boron trifluoride when packaged as specified and transported by highway, rail, vessel, or as cargo on an aircraft. 

You describe the construction of a neutron radiation detection system and your proposal to place a sufficient quantity of activated alumina or activated carbon desiccant within a sealed outer moderator that also acts as the outer case of the system.  The outer moderator which is made of polyethylene also encases the detector probe containing the boron trifluoride.  You ask if this described method of packaging meets the intent of the requirements of paragraph a.(4) of Special Provision 238.

As described, the neutron radiation detection system would meet the requirements Special Provision 238 paragraph a.(4) relating to the requirement for a liner surrounding the detector.  The sealed polyethylene outer moderator would serve as the required liner.

Provided the radiation detector meets all other requirements of paragraph (a) of Special Provision 238 and the system is packaged in a strong outer packaging capable of withstanding a 1.8 meter (6-foot) drop without leakage, or the system itself, without packaging is capable of withstanding a 1.8 meter (6-foot) drop without leakage, the described radiation detection system is eligible for the relief from the HMR provided by paragraph (c) of Special Provision 238.

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

172.102(c)(1)

Regulation Sections