{"operation":"document","citation":"06-0190","title":"RWE NUKEM Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-10-03","effective_on":null,"summary":"06-0190 response to RWE NUKEM Corporation concerning 172.203, 173.433.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0190.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0190.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0190","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060190.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nОСТ З 2006\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration\nMr. Stan Hodges\nRWE NUKEM Corporation\nRef. No.: 06-0190\n3800 Fernandina Road\nSuite 200\nColumbia, SC 29210-3854\nDear Mr. Hodges:\nThis is in response to your August 14, 2006 letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if\ninclude the activity of all radionuclides in the package, the activity of all parent\nthe total activity required to be entered on shipping papers for radioactive materials must\nradionuclides in the package, or only the activity of the radionuclides that are required to\nbe listed on a shipping paper per § 172.203(d)(1).\nSection 172.203(d)(3) requires the total activity contained in each package of the\nthe shipping paper must be the sum of the activities of all radionuclides present in the\nshipment to be included on the shipping paper. The activity required to be included on\npackage, including those of both parent radionuclides and daughter products.\ncontact this office.\nI hope this information is helpful. If you have further questions, please do not hesitate to\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n172.203 (d)\n173-433(9)\n060190\n\n<<<PAGE 2>>>\n\nMessage\nEichenlaub\nPage 1 of 2\n8172.203\nDrakeford, Carolyn <PHMSA›\n• 8 | 13.4939.\nShipping Papers KAM\nFrom:\nWilliams, James <PHMSA>\n06 - 0190\nSent:\nTuesday, August 15, 2006 1:43 PM\nTo:\nDrakeford, Carolyn <PHMSA>\nSubject:\nFW: Interpretation\nAttachments: DOT - Mazzullo - A2 values & Activity Questions Itr dtd 020128.pdf; DOT - Mazzullo It dtd\n020128.pdf\nInterpretation Request\nJim Williams\nFrom: Stan Hodges [mailto:shodges@nukem.com]\n-----Original Message--..\nSent: Monday, August 14, 2006 5:37 PM\nSubject: Interpretation\nTo: Williams, James <PHMSA>\nJim:\nthat I submitted and the 2nd attachment is the document that I just scanned along with the fax cover page). For\nBack in 2002, I submitted the attached letter for review and interpretation (the first attachment is the actual letter\nthe life of me, I cannot find where I ever received a response - pls note that this letter was submitted before the\nlatest revision to the regulations. I also searched the DOT HMR web site and I also could not find a response. I\nnave a basic question that I would like to get answered as soon as possible.\nunits be included an additional entry relative the description of Class 7 (radioactive) material on the shipping\n1. 172.203(d)(3) requires that the activity contained in each package of the shipment in terms of appropriate SI\npapers. Here is my big question:\nnoted in 172203(d)(1); or\nA. Is this activity only the activity of the radionuclides that must be listed on the shipping papers per 173.433(g) as\nC. Is this activity the total activity of all parent radionuclides in the package [above and beyond those required to\nB. Is this activity what is required in A. above plus the applicable daughter products of these nuclides; or\nbe listed in 173.433(g) or 172.203(d) (1)]; or\nproducts)?\nD. Is this activity the total activity of all radionuclides in the package (including both parent and daughter\nThanks in advance for your quick turnaround. I believe a lot of popular shipping programs only utilize the activity\nThanks in advance for your quick turnaround. I will also take a look at the ST-1 guidance that you provided to m\no see what IAEA had to say about the topic\nStan Hodges\n(0) 803-214-5848\nSr Project Manager\n(M) 803-318-7493\n8/17/2006","truncated":false,"body_characters":3595}