{"operation":"document","citation":"05-0082","title":"United States Regulatory Commission — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-04-14","effective_on":null,"summary":"05-0082 response to United States Regulatory Commission concerning 173.416.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0082.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0082.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0082","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050082.pdf","body":"<<<PAGE 1>>>\n\nJ.S. Departmen\nf Transportatior\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline cind\nHazardous Materials Safety\nAPR 14 2005\nAdministration\nMr. David Pstrak\nRef. No. 05-0082\nNuclear Material Safety and Safeguards\nSpent Fuel Project Office - 13D13\nUnited States Nuclear Regulatory Commission\nWashington, D.C. 20555-0001\nDear Mr. Pstrak:\nThis responds to your letter of April 7, 2005, requesting clarification as to whether a shipper\nthat has drilled holes in a \"Type A package\" must perform an analysis on the package to\nconfirm that no contents would be released.\nThe answer is yes. It is the opinion of this office that if holes are drilled in a package that\nwas previously demonstrated to satisfy the \"Type A package\" performance requirements, the\npackage would no longer be identical to the previously designed and tested package\nTherefore, a \"Type A package\" that has holes drilled in it, may not continue to be designated\nas a \"Type A package\" until it has been completely evaluated against the specifications\nspecified in §' 178.350. That evaluation may be conducted using any of the methods described\nin § 173.461(a), or a combination of them, and documented in accordance with § 173.415(a).\nI trust this satis les your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nCass\nDong\nSusan Gorsky\nActing Director, Office of Hazardous\nMaterials Standards\n050082\n173.416\n\n<<<PAGE 2>>>\n\nFerate, Fred <PHMSA>\nLisinte set\nSent\nFrom:\nDave Pstrak [DWP1@nrc.gov]\nBetts\nCc:\nTo:\n113.416\nSubject:\nFwd: Question of drilling holes in Type A containers\npackages\n05-0082\nQuestion of drilling\nholes in...\nGentlemen,\nHere is and incoming email from Region IV concerning drilling of holes in Type A packages.\nI'd like to get DOT's thoughts on this.\nvould be released? It seems reasonable to say that the contents of a gauge would not fit through a hole that is plugge\nould a shipper who has put holes in a Type A container perform an analysis on the container to confirm that no content\nwith a bolt. I don't wart to promote putting holes in Type A packages, but if one can prove that the integrity is maintained,\nPlease let me know your thoughts.\nThanks!\nDavid\n\n<<<PAGE 3>>>\n\nFerate, Fred <PHMSA>\nFrom:\nSent:\nJames Thompson jit3@nrc.gov]\nCc:\nTo:\nDave Pstrak\nThursday, March 10, 2005 4:23 PM\nSubject:\nJeffrey Cruz\nQuestion of drilling holes in Type A containers\nMr. Pstrak,\nThis is a followup email regarding our telephone conversation today about the above subject.\nApparently, in an effort to comply with the new security requirements for portable gauges, some licensees are bolting the\nsecuring the Type A container to a metal box via bolts. The question arose during inspection debriefs as to whether DOT\nportable gauge containers (Type A 7A) via holes drilled into the container, directly into the bed of a pickup truck, or\nAould consider this drilling of holes and bolting of the Type A container as a compromise of the integrity of the DOT Type\nThese bolts are only an inch or two long, just enough to hold the package firmly into place. The holes do not appear to be\nn the immediate vicinity of the gauge itself, merely on the outside perimeter of the container\nrequirements of these portable gauges.\nThe inspectors in the \"ield greatly appreciate your assistance in answering these questions regarding the new security\nRIV/NMIB\n-James L. Thompson","truncated":false,"body_characters":3386}