SAIC Health Physicist — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department 400 Seventh St., S.W. Special Programs Research and APR 16 2003 Washington, D.C. 20590 Administration Ms. Linda G. Bray SAIC Health Physicist Reference No. 03-0071 16701 West Bernardo Drive San Diego, CA 92127 Dear Ms. Bray: This responds to your letter requesting clarification of the labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask if the "activity" and "transport index" values, when required on a RADIOACTIVE label, may be expressed as less than (<) the maximum initial starting value. You state that you wish to use permanent labels on a Type A package installed in a Mobile Vehicle and Cargo Inspection System (Mobile VACIS) and that the "activity" and "transport index" values decrease over a time period of between 8 to 15 years. You also reference a previous clarification letter regarding the use of a permanent shipping paper that remains with the vehicle for its life time (Reference No. 02-0116, June 4, The answer to your question is no. There are no provisions in the HMR to express the value of the "activity" or the "transport index" of a RADIOACTIVE label in a manner other than the actual value. Our letter of clarification regarding the permanent shipping paper states that the same shipping paper may remain with the Mobile VACIS for its lifetime provided the content (including quantity) of the Type A package remains the same and the Type A package is not reshipped or transferred to another vehicle. If the content (including quantity) of the Type A package changes (i.e. decreases over time), a new shipping paper would have to be prepared and new RADIOACTIVE labels reflecting the decreased "activity" and "transport index" affixed to the Type A package. Since radioactive material decays, we suggest that you may wish to prepare a new shipping paper and affix a new label reflecting the new level of activity periodically. I hope this satisfies your request. Sincerely Hothe 2. mitheel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 030071 113#

Page 2Corbin AIC. $173.403 Science Applications International Corporation An Employee-Owned Company _abeline March 4, 2003 13-0071 Edward Mazzullo Director Office of Hazardous Material Standards USDOT/RSPA (DHM)-10 400 Seventh St. S.W. Washington, D.C. 20590 Subject: Request for Clarification of Label Documentation shipping paper and contamination control requirements. Reference: 02-0116, Letter from Hattie Mitchell to James Price, regarding clarification of Dear Mr. Mazzullo, SAIC produces a Mobile Vehicle and Cargo Inspection System (Mobile VACIS), which These syd mos inside a tal and international Truck, ang contripsand vel seni- permanently mounted gauge device (Type A package) containing either a Cs-137 source or a Co-60 source. The Cs-137 source has a maximum activity of 59GBq (*15%) and the Co-60 source has a maximum activity of 37 GBq (‡ 25%). These devices have been 0215-D-103S and CA-0215-D-107S. approved for use by Specific Licensees under Sealed Source and Device Registries CA- The gauge housing is a DOT Type 7A package, and the source remains in the gauge 0116) a letter of clarification regarding the use of a single shipping paper, that remains with the vehicle for its lifetime. attach new hazard labels for each movement. The use of the < symbol allows the end 16701 West Bernardo Drive, San Diego, CA 92127#

Page 3user to have a consistent method for labeling and understanding the hazard levels associated with the system. (There are over 70 Mobile systems in service). SAIC noted that the regulations for labeling specified in 49 CFR 172.403 allow the use of abbreviations for the source activity, but do not specify that for the T.I. value. Neither section specifically address the use of the < symbol. Since the sources will typically stay packaged for transport with the systems for between 8 to 15 years, it is understood that the T.I. value and activity will decrease over time. However, labeling of the worst case initial activity seemed the most prudent approach. SAIC is requesting clarification and source activity for the permanent labels. approval for the use of the < symbol for the maximum T.I. value and maximum initial Thank you for your attention regarding this matter and should you have any additional questions or concerns please contact me at your carliest convenience. Linda SAne Heath Physicist Fax.: Tel.: (858) 826-9664 (858) 826-9224#

Page 4RADIOACTIVE II CONTENTS: Cobalt-60 ACTIVITY: <37 GBq (1.0Ci) < 1.0 TRANSPORT INDEX 7 Attachment 2#

Page 5RADIOACTIVE II CONTENTS: Caesium-137 ACTIVITY: <59 GBq (1.6 Ci) < 1.0 TRANSPORT INDEX 7 Attachment 1#