Regulatory Resources, Inc. — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Hazardous Materials Safety Pipeline and Administration DEC 13 2005 Mr. Wade Winters Ref. No. 0.5-0279 Regulatory Resources, Inc. 240 Joshua Road Kennewick, WA 99338 Dear Mr. Winters: This is in response to your November 1, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the free drop test for Type 7A packages specified in § 173.465(c). It is your understanding that center of gravity over impact point testing is not a required drop test orientation for a Type 7A package, unless such an orientation would inpart maximum damage to the package. Your understanding is correct. A Type 7A package, with its contents, must be capable of withstanding a free drop test. The specimen must drop onto the target so as to suffer maximum damage to the safety features being tested. The person conducting the free drop test must determine the orientation that will produce the maximum damage. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, 173.465 (e) 050279#

Page 211/01/2005 14:49 FAX 509 628 0972 Regulatory Resources Inc 4002/003 Lear §173.465 (c) Regulatory 240 Joshua Roa Resources ne. Test Voice: 50-622-932 fax: 509-628-0972 "The Source You Come Back To". 05.0279 ade@regulatoryresources.r ww.regulatoryresources./ November 1, 2005 Ms. Susan Gorsky Oftice of Hazardous Materlals Standards Pipellne and Hazardous Materials Safety Administration PHH-10 U.S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590 Dear Ms. Gorsky, Department of Transportation (DOT) Hazardous Materlals Regulations (HMRs) and the Environmental Regulatory Resources, Inc. (RRI) is a consulting and training company serving clients subject to the Protection Agency (EPA) solid and hazardous waste management regulation. One of our speclaity areas covers the regulations for the safe transport of radioactive materlals. Various Class 7 packaging questions have been ralsed in recent training classes and I'm seeking PHMSA's clarification on these. RRI Is seeking PHMSA concurrence as to the intent of 'maximum damage' concerning Type A package drop tests. We test orlented with its center of grovity over the polnt of Impoct. do not belleve that orientation for maximum damage is the same as requiring the package to be drop fissile solids must be dropped onto the target (e.g.. unyielding surface) so as to suffer the maximum The 49 CFR 173.465(c), Type A packaging tests, Free drop test, states that the package containing non- damage to the safety features being tested. Paragraph (c)(1) identifles the required free drop distance based on package mass. This drop test requrement Is a test performed to simulated 'normal conditions of transportation'. The purpose of this test Is to reproduce the type of shock and damage that could be experlenced if the package were to fall off a vehicle or loading dock. or if were to be dropped during occurrences. normal handling. The test is not designed to simulate vehicle accident situations or accident type handling The objective of the Type A package drop test is to inflict 'maximum damage' to evaluate the package features such as structural components, containment systems, closures, and shielding configurations and properties. To achieve maximum damage the package may require several drops in varying drop configurations, however, all possible drop orientations need not be considered providing that these drop arlentations are not possible under normal conditions of transport. Naturally, these determinations must be documented by the package designer and/or test engineer. As stated by the IAEA in TS-G-1.1, 1722.6: "During the revision process leading to the 1996 edition of the Regulations, It was agreed that all possible drop test orientations need not be considered when conducting the drop test for package to be dropped in certain orlentations, these orientations could be ignored in assessing normal conditions of transport. Providing that it is not possible under 'normal' conditions for the the worst damage. It was envisaged that this relaxation would only be allowed for large justification by the package designer." dimension and large aspect ratio packages. In addition this relief would require documented#

Page 311/01/2005 14:49 FAX 509 628 0972 Regulatory Resources Inc @003/003 240 Joshua Road Regulatory Resources, inc Voice: 509-628-1020 Kennewick, WA 99338 www.regulatoryresources.net Fax: 509-628-0972 November 1, 2005 Ms. Susan Gorsky Page 2 For example, a package with a relatively large aspect ratlo (e.g., 4' wide x 4' high × 25' long) must be tested and evaluated based on its normal loading and handling configuration so that maximum damage is attained. Some users of Type A radioactive materials packagings require the manufacturer to test the normal condition of transport as this orientation may not be within the scope of the design for the handling package with Its center of gravity over the point of impact. The result of such test may be beyond any and transport configuration of the package. Clearly, such a drop configuration wil sublect secondary Impacts that far exceed any normal condition drop test requrement. RRI seeks PHMSA concurrence that center of gravity over impact point testing, based on the design of the package as documented by the design and/or test engineers, Is not the same as the requirement to test the package so that'maximum damage' Is Imparted to the package under normal conditions of transport. orlentation unless such package orlentation would, in fact, impart maximum Impalment to the integrity Furthermore, we believe that center of gravity over impact point testing is not a required drop test of the package under normal condition of transport. Thank you for your time in these matters. Please contact me if I can answer any questions. For Regulatory Resources, Inc., Wade A. Winters, CET, CHMM President WAW/lom#