Volunteer Drum — Hazardous Materials Safety Interpretation

Page 1S. Departme Transportatic Wash ngton, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration MAR 1 2007 Volunteer Drum R. Jack Oody Ref. No.: 07-0004 3311 John Sevier Hwy Knoxville, TN 37914 Dear Mr. Oody: This is in response to your December 22, 2006 letter and subsequent telephone conversation with Ben Supko of my staff requesting clarification of performance oriented packaging requirements contained in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a UN1A2 packaging that is embossed with a complete marking for liquids in PG II and partial marking for solids in PG I, missing the UNIA2 portion of solid marking, is a suitable packaging for a material classed as embossed on the bottom, you indicate that the packaging is dual marked on the side with the complete markings as required by § 178.503(a). In a final rule published under Docket HM-230 (69 FR 3632; January 26, 2004) we indicated our intention to remove paragraphs (a)(1), (a)(2), (a)(6), (b)(1) and (b)(2) of § 173.417 and discontinue the use of DOT Specification 6L, 6M, and 1A2 containers as authorized fissile materials packagings. However, in accordance with § 173.417(c), continued use of existing inventories is authorized until October 1, 2008. provided the packaging conforms with all requirements in effect on October 1, 2003, In accordance with the requirements in effect on October 1, 2003, the 55 gallon drum must be a UN1A2 packaging that has been marked and tested at the PG I performance level in accordance with Part 178, Subparts L and M, respectively. The packaging you describe is not a UN1A2 packaging because it is not marked in accordance with all the requirements in § 178.503. As specified in § 178.503(a)(10), each new UN rated drum over 100 L must ›e permanently marked on the bottom with the marks required in paragraphs (a)(1)-(a)(6) and 9) of § 178503. Therefore, the packaging you describe is not an acceptable packaging for a material classed as "Radioactive material, Type A package, fissi e; I hope this information is helpful. Please contact us if you require additional assistance. 113.417 070004 178.503 Office of Hazardous Materials Standards#

Page 2Supko Page 1 of 1 3178.503 Drakeford, Carolyn <PHMSA> $178.504 From: Gorsky, Susan <PHMSA> Markings Sent: Wednesday, January 03, 2007 12:09 PM 04-008 To: Drakeford, Carolyn <PHMSA> Subject: FW: Evans marked drums Please enter this as a request for interpretation. Thanks. Susan From: Drumman43@aol.com [mailto:Drumman43@aol.com] To: Gorsky, Susan <PHMSA> Sent: Friday, December 22, 2006 9:44 AM Subject: Evans marked drums Susan Gorsky US Government Department of Transportation December 22, 2006 a solid hazardous waste? The drum has both complete markings on the side UN1A2/Y1.6/200 Susan is a drum that is dual embossed on the bottom UN1A2/Y1.6/200 /X423/S suitable or packaging for low level radioactive waste. Even though the UN1A2 is missing from the solid rating on the bottom of the UN1A2/X423/S, has four 1/2" holes drilled in the top circumference and is to be used as an outer package drum, can it be used for this purpose, and under what Specification is it approved or disapproved? Volunteer Drum R. Jack Oody 865-673-9396 Drumman43 @AOL.com 1/3/2007#