Bechtel Hanford, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation FEB 14 2003 400 Seventh St., S.W. Special Programs Research and Washington, D.C. 20590 Administration Mr. J. M. Atwood Bechtel Hanford, Inc. Manager, Waste Management/Transportation Reference No. 03-0013 3350 George Washington Way Richland, WA 99352 Dear. Mr. Atwood: This is in response to your letter dated January 13, 2003 requesting a clarification of the packaging requirements for Uranium metal, pyrophoric, UN2979, under the Hazardous Materials Regulations (49 CFR Parts 171-180). Specifically, you ask what test criteria must the packaging configuration meet. Section 173.418 requires pyrophoric Class 7 (radioactive) materials in quantities not exceeding Az per package to be transported in DOT Specification 7A packagings constructed of materials that will not react with, nor be decomposed by, the contents. In addition, the contents of the package must among other things be inerted to prevent self-ignition during transport by either: suitable inerting material, or blended into a matrix of hardened concrete; or (1) Mixing with large volumes of inerting materials, such as graphite, dry sand, or other (2) Filling the innermost receptacle with an appropriate inert gas or liquid. In your letter, you stated that your depleted uranium is packaged in small drums (nominally 30 gallons) tilled with mineral oil as a liquid inerting agent. You further stated that, the small drum is then placed inside a larger (nominally 55 gallons) DOT Specification 7A package. Therefore, your DOT Specification 7A package must conform to the Type A packaging tests prescribed in §§ 173.465 and 173.466. I hope this satisfies your request. Sincerely, Hothe z. mitthal Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 173.418 030013#

Page 2Job No. 22192 BECHTEL Written Response Required: NO Closes CCN; N/A Actionee: N/A N/A OU: 105032 TSD: N/A N/A BRA: N/A Subject Code: 8515 Betts JAN 1 3 2003 $173.418 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards RAM U.S. DOT/RSPA (DHM-10) 400 7th Street S. W. Washington, D.C. 20590-000 03-0013 Subject: INTERPRETATION OF 49 CFR 173.418 Dear Mr. Mazzullo: In order to ensure that we are conducting our transportation activities in a compliant manner, was Pyrophonic. Specifically, we are packaging depleted uranium chips and turnings that are considered to be pyrophoric. The depleted uranium is packaged in small drums (nominally 30 gallons) filled with mineral oil as a liquid inerting agent. The mineral oil does not meet the DOT definition of a radioactive material (i.e., it is less than 70 Bq/gram). However, it is slightly contaminated with specification 7A container. All of this is intended to be in full compliance with 49 CFR 173.418. radioactive material. The small drum is then placed inside a larger (nominally 55 gallons) DOT A iSsue 15 Whatrestantena the packaging configuration ust meet. Three different scenarios have been put forward, either by the regulated community, or by the help line. These are: 1) The material being shipped is a solid. The liquid has been added for purposes of packaging considered to meet the test requirements if there is no loss of radioactive materials (i.e., packaging reference of 173.213). BECHTEL HANFORD, INC. sand A 4952 gon Way el (509) 375-464 ax (509) 375-464#

Page 3E. T. Mazzullo 105032 Page 2 during the testing. 3) in 49 CFR 173.466. The material being shipped is a liquid and must meet the test requirements for a liquid found If you have questions or need additional information, please don't hesitate to contact me at (509) 372-9343 or jmatwood@bechtel.com. Thank you for your response to this request. Sincerely. J. M. Atwood Manager, Waste Management/Transportation JMA:nww#