N. Wood Counter Laboratory, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous MAY 18 2007 Materials Safety Administration Ms. Marjory Crawford Reference No.: 07-0093 P.O. Box 2509 N. Wood Counter Laboratory, Inc. Chesterton, IN 46304 Dear Ms. Crawford: This responds to your May 3, 2007 letter and our telephone conversations concerning the transportation of certain hermetically sealed nuclear radiation sensor (detector) tubes atmospheric pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts containing less than one gram of Boron trifluoride, 2.3, Hazard Zone B, at less than 171-180). We reviewed the information submitted on the hermetically sealed detector tubes, each containing not more than one gram of Boron trifluoride filled to less than atmospheric are not subject to the HMR. unreasonable risk to health, public safety or property during transportation and, therefore, I hope this information is helpful. Please contact this office if we can be of further assistance. Sincerely. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Safety 171.2 070093#

Page 2Mitchell 3,171.2 Applicability 07-0093 N. WOOD COUNTER LABORATORY, INC. RADIATION DETECTORS SINCE 1949 P.O. BOX 2509 • CHESTERTON, INDIANA 46304 USA • TEL (219) 926-3571 • FAX (219) 926-6662 May 3, 2007 Ms. Hattie L. Mitchell Office of Hazardous Material Standards Chief, Regulatory Review and Reinvention FAX Number: (202) 366-7435 U.S. Dept. of Transportation lashington. DC 2059 00 Seventh St. S. V RE: Our A.M. Conversation Dear Ms. Mitchell, We urgently need a letter updating the DOT letter of February 1984 (addressed to The N. Wood Counter Laboratory, Inc.). I am enclosing the nineteen (19) pages | received yesterday (May 2, 2007) as you requested. This communication illustrates the confusion caused by the federal HAZMAT shipping regulations which apply to tanks of compressed Bf3. Compressed Bf, is the way manufacturers receive Bf, from sources such as Eagle Picher. Tanks of Bf, are shipped on trucks in crates with HAZMAT labels which is how we and LND receive Bf, to use in the manufacture of Bf, tubes. Helium 3 tubes are another type of neutron detectors net interchangeable with Bf, tubes in portable instruments. Some customers of Bf, neutron detectors think they can avoid shipping problems by "switching" to HE 3 tubes. An updated letter to the 1984 letter would solve both of these problems. Thank you for your kind attention to this matter. Sincerely, President, N. Wood Laboratory, Inc. Marjory Wood Crawford#

Page 3of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety April 2, 2007 N. Wood Counter Laboratory, Inc. Ms. Marjory Crawford P.O. Box 509 Chesterton, IN 46304 Dear Ms. Crawford: your company's radiation detector tubes containing less than one gram of boron In a February 9, 1984 letter, we provided you with a determination regarding certain of trifluoride, filled to less than atmospheric pressure, and overpacked in a specially designed packaging. We informed you that due to the form and limited quantity of boron trifluoride contained in the radiation detector tubes, these devices, when packed and offered for shipment as described in your letter were not subject to the Hazardous Materials Regulations. A copy of the letter is enclosed. of these devices. Please contact me at (202) 366-8553 if you have any questions We would appreciate your providing us with an update on the transportation experience concerning this request. Sincerely, Hotte CAt Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention Enclosure#

Page 41AY- 31-86 WED 01:00 PM M•HOOD COUNTER LABORATOR 219 938 35}, mal on shens .. FAX/292209412 JEROM MARDORK ORAND FEB - 1904 Dor Lets Ma. Harjory Crawford N. Wood Counter Leboratory, Ino. Vice President 2525 Fast 53rd Street Chicago, Illlnote 60615 Dear Ma. Crawford: requenting en exemption authorizing the transportation of radiation Ile is to reterento to youx application dated Juaxy 31, 1984, fluorida gass toredo tube are tagged to less shen at he do press end at- overpacked in a specially dealgaad perkaging. Due to the for detectox tuben, these devices, when packed and offered for shipuent to l1fe or property durlug transportation and, therefoxe, axe not as described lu your application, are not construed to pose a ximi considered subject to the Hazardous Materials Ragulationa, 49 CM sincerely, ALE I BOREHIS • • • Atra I. Roberta Associate Director for Hazaxdous Meteriala Tranaportation ButeRu Matertale Regulation Enclosure#