{"operation":"document","citation":"06-0084","title":"RWE NUKEM Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-06-07","effective_on":null,"summary":"06-0084 response to RWE NUKEM Corporation concerning 173.403.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0084.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0084.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0084","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060084.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh Street, S.W\nWashington, D.C. 20590\nPipeline and\ndministratiol\nlazardous Materials Safer\nJUN 7 2006\nMr. Stan Hodges\nRWE NUKEM Corporation\nReference No.: 06-0084\n3800 Fernandina Road\nSuite 200\nColumbia, SC 29210\nDear Mr. Hodges:\nThis responds to your letter concerning the use of freight containers as Industrial packages\nTypes 2 or 3 (Type IP-2) or (Type IP-3) under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:\nthe Safe Transport of Radioactive Material (TS-R-1) authorizes the use of freight\nQ1. Paragraph 627 of the International Atomic Energy Agency's (IAEA) Regulations for\nthe accelerations occurring during routine conditions of transport they would prevent:\n(a) loss or dispersal of the radioactive contents; and\n(b) loss of shielding integrity which would result in more than a 20% increase in\nthe radiation level at any internal surface of the freight container.\nWhat type of calculation would be needed to prove the requirements have been met?\nAl. Any of the methods described in paragraphs 701 and 702 of IAEA's TS-R-1\n(incorporated by reterence in § 171.7) may be used to demonstrate compliance with the\nCompliance with the test standards may be accomplished by any one of the following\n(1) Performance of tests with specimens representing LSA-III material, or special\norm radioactive material, or low dispersible radioactive material or with prototypes (\namples of the packaging, where the contents of the specimen or the packaging for the tesi\nshall simulate as closely as practicable the expected range of radioactive contents and the\nspecimen or packaging to be tested shall be prepared as presented for transport.\n060084\n173.403\n\n<<<PAGE 2>>>\n\n(2) Reference to previous satisfactory demonstrations of a sufficiently similar\nnature.\nfeatures which are significant with respect to the item under investigation when\n(3) Performance of tests with models of appropriate scale incorporating those\nWhen a scale model is used, the need for adjusting certain test parameters, such as the\nengineering experience has shown results of those tests to be suitable for design purposes.\npenetrator diameter or the compressive load, shall be taken into account.\n(4) Calculation, or reasoned argument, when the calculation procedures and\nparameters are generally agreed to be reliable or conservative.\nQ2. May closed packages be placed inside a freight container if the packages are properly\nblocked and braced to prevent movement relative to the accelerations occurring during\nroutine conditions of transport?\nparagraphs 701 and 702 of TS-R-1, can demonstrate that the conditions in paragraph 627\nA2. The answer is yes, provided the shipper, using any of the methods described in\nof TS-R-1 have been satisfied.\nbe blanked off and HEPA filters installed when closed containers of radioactive materials\nQ3. If a freight container is equipped with passive vents, are the passive vents required to\nare transported in the freight container?\nsuccessfully met the IAEA TS-R-1 paragraph 627 test requirements.\nA3. The answer is no, provided the freight container and its radioactive contents have\nI trust this satisfies your inquiry.\nSincerely\nHotle a mattle\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nMessage\nCorbin\nPage 1 of 3\n$173.403\nWilliams, James <PHMSA>\nRAM\nFrom: Stan Hodges [shodges@rwe.nukem.com]\n06-0084\nSent:\nThursday, April 13, 2006 9:48 AM\nTo:\nWilliams, James <PHMSA>\nSubject: RE: IAEA Requirements for IP-2 Containers\nJim:\nOur company name and address is provided below:\n3800 Fernandina Road\nRWE NUKEM Corporation\nSuite 200\n803-214-5800\nColumbia, SC 29210\nI have also inserted the name/address in the initial e-mail message that I sent you a couple of days ago.\nStan Hodges\n(0) 803-214-5848\nSr Project Manager\n(F) 803-214-5804\n(M) 803-318-7493 (Note - New Number)\nSent: Wednesday, April 12, 2006 3:06 PM\nFrom: James. Williams@dot.gov [mailto:James.Williams@dot.gov]\nSubject: RE: IAEA Requirements for IP-2 Containers\nTo: Stan Hodges\nStan,\nCould you add your company name and address to this email.\nJim Williams\nRadioactive Materials Branch, PHH-23\nPipeline and Hazardous Materials Safety Administration\nOffice of Hazardous Materials Technology, Room 8430\n400 Seventh Street, S.W.\nU.S. Department of Transportation\nWashington, D.C. 20590\nJames. Williams@dot.gov\n4/13/2006\n\n<<<PAGE 4>>>\n\nMessage\nPage 2 of 3\n(202) 366-6177\nFrom: Stan Hodges [mailto:shodges@rwe.nukem.com]\n-----Original Message--.--\nTo: Williams, James <PHMSA>\nSent: Monday, April 10, 2006 10:30 AM\nSubject: IAEA Requirements for IP-2 Containers\nJim:\nsection from the updated IAEA regulations that allow the utilization of freight containers as Type IP-2\nThanks for taking the time to discuss Section 627 of the IAEA regulations with me today. Here is the\ncontainers provided that they conform to the standards prescribed in the ISO document ISO 1496/1. The\ndocument and the accelerations occurring during routine conditions of transport they would prevent: (i) los:\nsection does however note that they shall be designed such that if subjected to the tests prescribed in that\nor dispersal of the radioactive contents; and (ii) loss of shielding integrity which would result in more than a\n20% increase in the radiation level at any external surface of the freight containers.\nHow do we prove this? What type of calculation would you need to do to prove items (i) and (i) below?\n627. Freight containers may also be used as Type IP-2 or Type IP-3, provided that:\n(a) The radioactive contents are restricted to solid materials;\n(b) They satisfy the requirements for Type IP-1 specified in para. 621; and\n(c) They are designed to conform to the standards prescribed in the International Organization for\nconditions of transport they would prevent:\n(i) loss or dispersal of the radioactive contents; and\n(ii) loss of shielding intégrity which would result in more than a 20% increase in the radiation level at any\nexternal surface of the freight containers.\nblocked and braced to not move relative to the accelerations occurring during routine conditions of\nWould placing closed packages inside of the freight container be sufficient if the packages were properly\ntransport?\n~ Freight containers are typically provided standard with passive vents. For containers that were being\npassive vents be blanked and HEPA filters) installed on the freight containers?\nutilized to ship radioactive packages (even in closed containers inside of the freight container), should the\no a nuclear power station in Spain via Liverpool, Engiland. If at all possible, we would like DOT's respons\nPlease note that we plan to ship containers with this exclusion either the first or second week of May 200\nas soon as possible.\nStan Hodges\n(0) 803-214-5848\nSr Project Manager\n(F) 803-214-5804\n(M) 803-318-7493 (Note - New Number)\n3800 Fernandina Road\nRWE NUKEM Corporation\n4/13/2006\n\n<<<PAGE 5>>>\n\nInput from Jim Williams\nThe DOT interpretation is any of the method(s) provided in paragraphs 701 and 702 of the IAEA TS-R-1\nRegulations may be used to demonstrate compliance with the paragraph 627 requirements.\nPara 701 Demonstration of compliance with the performance standards required in Section VI shall be\naccomplished by any of the methods listed below or by a combination thereof.\n(a) Performance of tests with specimens representing LSA-III material, or special form radioactive material, or\nlow dispersible radioactive material or with prototypes or samples of the packaging, where the contents of the\nspecimen or the packaging for the tests shall simulate as closely as practicable the expected range of\nradioactive contents and the specimen or packaging to be tested shall be prepared as presented for transport.\n(b) Reference to previous satisfactory demonstrations of a sufficiently similar nature.\nrespect to the item under investigation when engineering experience has shown results of those tests to be\n(c) Performance of tests with models of appropriate scale incorporating those features which are significant with\nsuitable for design purposes. When a scale model is used, the need for adjusting certain test parameters, such as\nthe penetrator diameter or the compressive load, shall be taken into account.\n(d) Calculation, or reasoned argument, when the calculation procedures and parameters are generally agreed to\nbe reliable or conservative.\nPara 702\nAfter the specimen, prototype or sample has been subjected to the tests, appropriate methods of assessments\nshall be used to ensure the requirements of this section have been fulfilled in compliance with the perfomance\nand acceptance standards prescribed in Section VI.\nIn accordance with paragraphs 627 of the IAEA TS-R-1 Regulations, freight containers may also be used as IP-\n2 or IP-3 packages, only as long all of the following four conditions are met:\na) The radioactive contents of the freight container are limited solid materials.\nb) The freight container meets the requirements for an IP-1 package.\nc) The freight container is designed to conform to the standards prescribed in: \"Series 1 Freight Containers -\nand ratings. It should be noted that freight containers approved in accordance with the International\nSpecifications and Testing - Part 1: General Cargo Containers for General Purposes; excluding dimemsions\nMaritime Organization International Convention for Safe Containers are not necessarily equivalent to the\ntesting prescribed by ISO 1496-1.\nd)\nThe freight container is designed such that if subjected to the tests prescribed in ISO 1496-1, as well as\nradioactive contents nor loss of shielding integrity which would result in more than a 20% increase ins\naccelerations occurring during routine conditions of transport, there would be no loss or dispersal of the\nradiation levels on any external surface of the freight container. It should be noted that the test conditions of\naccelerations occurring during routine conditions of transport are in addition to the testing prescribed by\nISO 1496-1 because the ISO Standard does not include dynamic tests.\nAs long as the four conditions described in paragraph 627 of the IAEA TS-R-1 Regulations can be\nvi demonstrated to be satistied by the shipper using any of the method(s) provided in paragraphs 701 and 702, then\nplacing properly blocked and braced closed packages inside a freight container would satisfy the Type IP -2 or\nIP-3 requirements.\n\n<<<PAGE 6>>>\n\nFreight containers with passive vents may or may not need HEPA filters(s) and/or to be blanked off to satisfy\nthe Type IP-2 or IP-3 requirements. Satisfactory demonstration of the requirements is incumbent on the\n* met, e.g., taking into account intermediate package containment systems, the freight containers would not\nb shipper, on a case-by-case basis. As long as all the requirements of paragraph 627 can be demonstrated to be\nnecessarily need to be HEPA filtered or blanked off.","truncated":false,"body_characters":11007}