Radian International — Hazardous Materials Safety Interpretation

Page 1• of Transportation US.Department Washington, S.C. 59 2059 Special Programs Research and Administration JUL &P3I 2001 Mr. Andrew Romach Reference No.: 01-0107 Regulatory Manager Radian International P.O. Box 13000 Research Triangle Park, NC 27709 Dear Mr. Romach: This is in response to your April 30, 2001 letter inquiring whether your light bulb meets the definition of a Class 7 (radioactive) material under 49 CFR 173.403. The light bulb contains a glass "starter bottle." The bottle's interior surface is coated with a solution containing a radionuclide. Specifically, you ask whether the specific activity is calculated by using the entire weight of the coated starter bottle or by using the actual weight of the coating. The specific activity is calculated by using the actual weight of the coating on the starter bottle. If the specific activity is 70 Bq per gram or lower, the light bulb does not meet the definition of Class 7 (radioactive) materials and is not subject to the Hazardous Materials Regulations. If the specific activity is greater than 70 Bq per gram, you may be able to offer the light bulb for transportation as a limited quantity material or surface contaminated object in an excepted package. This information addresses only the transportation of the light bulbs in question. We suggest that you review the U.S. Nuclear Regulatory Commission regulations in Title 10 of the Code of Federal Regulations regarding the use, possession and disposal of these light bulbs. I trust you find this information helpful. Sincerely, Hotte e ithell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2FROM URS RADIAN FAX NO.: 9194611371 04-30-01 81:04P P .01 . ° Corbin RADIAN INTERNATIONAL A DAMES & MOÖRE GROUP COMPANY' $173.403 April 30, 2001 Definitions Post Office Box 13000 Mailing Address: Research Triangle Park. Mr. Ed Mazzullo, Director 01-0107 North Carolina 27709 Research and Special Programs Administration Office of Hazardous Matcrial Standards Physical/Shipping Address: 1600 Perinterer Park Drive U.S. Department of Transportation Momsville, North Carolina 27560 400 7th Street, SW Washington, DC 20590-0001 912 461 1415 Fax 919 461 13(X1 Tel FAX: (202) 366-3012 Dear Mr. Mazzullo: I an writing to you to request a written regulatory interpretation conceming the correct approach for for determining whether or not this light bulb meets the definition of a "radioactive material" as set out in 49 calculating the specific activity of a light bulb that contains a radionuclide. Such interpretation is necessary CFR 173.403. This particular light bull contains a glass "starter bottle" (also called a "glow bottle"). The surface of this glass starter bottle has been coated with a solution that contains a radionuclide. (The specific radionuclide varies depending on the type of coating used.) DOT defines "radioactive material" in 49 CFR 173.403 as follows: Radioaclive material means any material having a specific activity greater than 70 Ba per gram (0.002 miorocurie per gram) (see definition of "specifio activily"). DOT defines "speoific activity" in 49 CFR 173.403 as follows: Specific uctivity of a radionuclide means the activity of the radionuclide per unit mass of that nuclide. The specific activity of a material in which the radionuclide is essentially uniformly distributed is the activity per unit mass of the material. To calculate the specific activity to determine whether or not this light bulb meets the definition of "radioactive material", would the calculation be performed using the entire wight of the coated starter bottle, or only the actual weight of the coating contained on the starter hottle? Please let me know if there arc any other factors to consider when calculating the specific activity for purposes of determining whether or not this light bulb meets the definition of a radioactive matcrial for hazardous material shipping. I appreciate your consideration of this matter. Regulatory Manager URS Corporation Engineering Services in North Caroline are performed through Radion intermational's wholly owned substdiary, Radian Engineering, Inc. Offices Worldwide#