{"operation":"document","citation":"02-0116","title":"Science Applications International Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-06-04","effective_on":null,"summary":"02-0116 response to Science Applications International Corporation concerning 173.443.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0116.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0116.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0116","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020116.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nResearch and\nof Transportation\nJUN\n4 2002\n400 Seventh St., S.W.\nWashington, D.C. 20590\nspecial Programs\nAdministration\nMr. James R. Price\nSenior Environmental Compliance\nReference No.: 02-0116\n& Health and Safety Officer\nScience Applications International Corporation\n10260 Campus Point Drive\nM/S B2-M\nSan Diego, CA 92121\nDear Mr. Price:\nThis is in response to your letter requesting clarification of the shipping paper and contamination\ncontrol requirements for radioactive materials under the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180). Your company operates Mobile Vehicle and Cargo Inspection Systems\nVACIS) to inspect the contents of truck\nevices and in cent thand. bash Mobile Antiner, care and passenger vehicles for explosiv\ngauge device (Type A package) containing either a 59 Gbq Cesium-137 or 37 Gibq Cobalt-60\nradioactive material sealed source.\nYour questions are paraphrased and answered as follows:\nQ1.\nScience Applications International Corporation (SAIC) prepares a shipping paper when\nthe Mobile VACIS first enters a public highway. Can the same shipping paper remain\nanother vehicle?\nwith the vehicle for its lifetime or until the Type A package is reshipped or transferred to\nA1.\nThe answer is yes. The same shipping paper may remain with the Mobile VACIS for its\nlifetime provided the content (including quantity) of the Type A package remains the\nsame or the Type A package is reshipped or transferred to another vehicle.\nQ2.\nSection 173.443(a) requires a determination of the level of non-fixed radioactive\nto putting the vehicle into service on a public highway. SAIC would perform subsequent\ncontamination. SAIC interprets this to mean that a wipe survey must be performed prior\nwipe surveys in accordance with the requirements of its Device Registry which requires\nleak testing prior to initial use and at intervals not to exceed 12 months. The techniques\nused would be capable of detecting 185 Bq of removable contamination. Additional\ncontamination surveys would not be required each time the truck is driven on a public\nhighway. Would our procedures satisfy the requirements of the HMR?\n173.443\n020116\n\n<<<PAGE 2>>>\n\nA2. Section 173.443(a) requires the level of non-fixed (removable) radioactive contamination\non the external surfaces of a package offered for transportation to be kept as low as\nreasonably achievable. The HMR require that the non-fixed radiation contamination not\nexceed the limits set forth in Table 11 and authorize the use of a wipe survey or other\nassessment method to check for non-fixed radioactive contamination. The HMR do not\nprescribe surveys at scheduled intervals. However, the shipper should have an\nassessment methodology in place to ensure compliance whenever the material is in\ntransport.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nHottle d. Mikhes\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nApr-17-2002 03:32pm\nFrom-SAIC\n858B269009\nT-621\nP. 002/004 F-624\nCorbin\nAlE.\n§172.200\nScience Applications International Corporation\nAn Employoo-Owned Company\n$173.443 (a)\nShipping Papers RAM\nIransmitted Via Facsimile\nApril 17, 2002\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Material Standards\n02-0116\nU.S. DOT/RSPA (DHM-10)\n400 7T ST. SW\nWashington DC 20590-0001\nRe:\nRequest for Regulatory Interpretation\nDear Mr. Mazzullo:\nScience Applications International Corporation (SAIC) appreciares your assistance in helping us\nVehicle and Cargo Inspection System (Mobile VACIS) product.\nclarify the applicability of the UJ.S. DOT Hazardous Material Regulations (HMRs) to our Mobile\nMobile VACIS is a truck-mounted gamma-ray imaging system (see picture attached) designed to\nnon-intrusively inspect the contents of mucks, containers, cargo and passenger vehicles for\nexplosive devices and/or contraband. Operators viewing Mobile VACIS radiographic images of\ntransportation of explosives, weapons and other threats. To accomplish this, each Mobile VACIS\nscanned cargo are able to quickly and easily identify hidden compartments associated with the\nis equipped with a semi-permanently mounted gauge device (Type A package) containing either\na 59 GBg Cesium-137, or a 37 GBq Cobolt-60, radioactive material sealed source. The vehicle\nof Radioactive Sealed Sources and Devices, Safety Evaluation of Device\" (Device Registry; No.:\nwith source does not require a hazardous material placard. The Mobile VACIS holds a \"Registry\nCA0215D103S for the Cs-157 unit and CA021SD107S for the Co-60) issued by the California\nlicensees. Mobile VACIS customers presently include various U.S. government agencies (U.S.\nDepartment of Health Services, as a U.S. NRC Agreement State, and is distribured to specific\nCustoms operates several dozen systems) and other non-govemmental parties.\nSubpart C of 49 CFR Part 172 requires each person who offers a hazardous material for\nransportation to describe the hazardous material on a shipping paper. SAIC has\nnterprered this requirement, as it relates to the use of the Mobile VACIS in commerce, a\n16707 West Bernardo Drive, San Diego, CA 92127\n\n<<<PAGE 4>>>\n\nApr-17-2002 09:32pm\nFrom-SAIC\n8588269009\nT-621 P.003/004 F-624\nMr. Edward T. Mazzullo\nApril 17, 2002\nPage 2\nnore Tical, he she package was to hop bed or mandered tom ne camiet\nruck was driven over a public highway\n2.\n49 CFR 173.443(a) requires, in part, a determination of the level of non-fixed radioactive\ncontamination by performing a wipe survey on the external surfaces of each package\noffered for transport. SAIC has interpreted this requirement, as it relates to the use of the\nover a public highway.\nYour timely assistance in this maner is greatly appreciated. If you have any questions with\nregard to the issues addressed in this lener, please don't hesitate to contact our technical\nrepresentative, Linda Bray at (858) 826-9664, or the undersigned at (858) 826-4359.\nSincerely,\nCIENCE APPLICATIONS INTERNATIONAL CORPORATION\nSenior Environmental Compliance\nJAMES R. PRICE\n& Health and Safety Officer\nAnachment\n\n<<<PAGE 5>>>\n\nApr-17-2002\n03:32pm\nFrom-SAIC\n8588269009\nT-621\nP.004/004 F-624\nPaop 1 nf 1\nDeLE MOD","truncated":false,"body_characters":6259}