Defense Logistics Agency — Hazardous Materials Safety Interpretation

Page 1Washington, D.C special program dministratio MAR 1 3 2001 Mr. F. Kevin Reilly Defense Logistics Agency Director Reference No.: 01-0064 Defense National Stockpile Center 8725 John J. Kingman Road, Suite 4616 Ft. Belvoir, Virginia 22060-6223 Dear Mr. Reilly: This is in response to your February 21, 2001 letter, inquiring whether your thorium nitrate hydrate may be offered for transportation as "Radioactive materials, LSA, n.o.s." under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that because of its highly hydrated state, the material has solidified into a non-friable indicate the material does not meet the defining criteria for a Division 5.1 under the test protocol rock-like monolith mass inside the packages during storage. Also, you state that prior testing in the United Nations Manual of Test and Criteria, "Classification Procedures, Test Methods and Criteria Relating to Oxidizing Substances for Division 5.1." Based on the information you provided, we concur that if the material meets the definition of Low Specific Activity (LSA) as defined in 49 CFR 173.403 and does not meet any other hazard class, it would be most appropriately described as "Radioactive material, LSA, n.o.s." I hope this information is helpful. Should you have further questions, please contact us. Sincerely, Hille 2. Mthele Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.101 010064#

Page 2DEFENSE LOGISTICS AGENCY Betts 3725 JOHN J. KINGMAN ROAD, SUITE 461€ DEFENSE NATIONAL STOCKPILE CENTER T. BELVOIR, VIRGINIA 22060-622: §172.101 Proper Shipping Nume. IN REPLY REFER TO 01-0064 DNSC-E FEB 2 1 2001 RSPA Office of Hazardous Materials Standards (DHM - 10) U.S. Department of Transportation 400 Seventh Street Washington DC 20590-0001 Dear Sir or Madam: The Defense Logistics Agency (DLA) Defense National Stockpile Center (DNSC) has over 2.3 million kg (5.1 million pounds) of Th(NO3)4.• 5H2O (thorium nitrate hydrate) in storage. Because of its highly hydrated state this material has solidified into a non-friable rock-like monolith inside the packages during storage. The thorium in this material has the naturally occurring isotopic distribution and has not been irradiated or isclopically concentrated The DNSC is considering transporting this material as part of a final disposition pian. Some prior testing of this material, performed at the direction of DNSC, indicates that the 5 hydrate form of thorium nitrate will not qualify as an oxidizer under the test protocol provided in the UN Manual of Test and Criteria "Classification Procedures, Test Methods and Criteria Relating to Oxidizing Substances for Division 5.1". If the UN Manual of Test and Criteria "Classification Procedures, Test Methods and Criteria Relating to Oxidizing Substances for Division 5.1" test protocol is performed on a representative sample of the Th(NO3)4 • 5H20 in the DNSC inventory and the material does not qualify as an oxidizer, can this material be classified, packaged, and shipped as "Radioactive materials, LSA, n.o.s"? Sincerely, ( E KEVIN REILIX/ Director, Directorate of Environmental Management & Quality Assurance Federal Recycling Program Printed on Recycled Paper#