RWE NUKEM Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department ОСТ З 2006 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration Mr. Stan Hodges RWE NUKEM Corporation Ref. No.: 06-0190 3800 Fernandina Road Suite 200 Columbia, SC 29210-3854 Dear Mr. Hodges: This is in response to your August 14, 2006 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if include the activity of all radionuclides in the package, the activity of all parent the total activity required to be entered on shipping papers for radioactive materials must radionuclides in the package, or only the activity of the radionuclides that are required to be listed on a shipping paper per § 172.203(d)(1). Section 172.203(d)(3) requires the total activity contained in each package of the the shipping paper must be the sum of the activities of all radionuclides present in the shipment to be included on the shipping paper. The activity required to be included on package, including those of both parent radionuclides and daughter products. contact this office. I hope this information is helpful. If you have further questions, please do not hesitate to Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 172.203 (d) 173-433(9) 060190#

Page 2Message Eichenlaub Page 1 of 2 8172.203 Drakeford, Carolyn <PHMSA› • 8 | 13.4939. Shipping Papers KAM From: Williams, James <PHMSA> 06 - 0190 Sent: Tuesday, August 15, 2006 1:43 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Interpretation Attachments: DOT - Mazzullo - A2 values & Activity Questions Itr dtd 020128.pdf; DOT - Mazzullo It dtd 020128.pdf Interpretation Request Jim Williams From: Stan Hodges [mailto:shodges@nukem.com] -----Original Message--.. Sent: Monday, August 14, 2006 5:37 PM Subject: Interpretation To: Williams, James <PHMSA> Jim: that I submitted and the 2nd attachment is the document that I just scanned along with the fax cover page). For Back in 2002, I submitted the attached letter for review and interpretation (the first attachment is the actual letter the life of me, I cannot find where I ever received a response - pls note that this letter was submitted before the latest revision to the regulations. I also searched the DOT HMR web site and I also could not find a response. I nave a basic question that I would like to get answered as soon as possible. units be included an additional entry relative the description of Class 7 (radioactive) material on the shipping 1. 172.203(d)(3) requires that the activity contained in each package of the shipment in terms of appropriate SI papers. Here is my big question: noted in 172203(d)(1); or A. Is this activity only the activity of the radionuclides that must be listed on the shipping papers per 173.433(g) as C. Is this activity the total activity of all parent radionuclides in the package [above and beyond those required to B. Is this activity what is required in A. above plus the applicable daughter products of these nuclides; or be listed in 173.433(g) or 172.203(d) (1)]; or products)? D. Is this activity the total activity of all radionuclides in the package (including both parent and daughter Thanks in advance for your quick turnaround. I believe a lot of popular shipping programs only utilize the activity Thanks in advance for your quick turnaround. I will also take a look at the ST-1 guidance that you provided to m o see what IAEA had to say about the topic Stan Hodges (0) 803-214-5848 Sr Project Manager (M) 803-318-7493 8/17/2006#