Washington Closure Hanford, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 MAY 0 1 2012 Mr. Robinson E. Fillmore Transportation and Packaging Lead Washington Closure Hanford, LLC 2620 Fermi A venue Richland, W A 99354 Ref. No. 11-0296 Dear Mr. Fillmore: This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking and labeling requirements of Class 7 (Radioactive) material packages. Specifically, you ask whether a dedicated-use transport vehicle and its designed-for and securely attached 18 cubic yard roll-on/roll-off industrial packaging may be considered as one "package" as defined in § 173.403 of the HMR for the purposes of marking and labeling. The answer is no. As defined in § 173.410: • Package means the packaging together with its radioactive contents as presented for transport, and • Packaging means, for Class 7 (radioactive) materials, the assembly of components necessary to ensure compliance with the packaging requirements of this subpart. It may consist of one or more receptacles, absorbent materials, spacing structures, thermal insulation, radiation shielding, service equipment for filling, emptying, venting and pressure relief, and devices for cooling or absorbing mechanical shocks. The conveyance, tie-down system, and auxiliary equipment may sometimes be designated as part of the packaging. If consideration of the conveyance as part of the package is not "necessary to ensure compliance with the packaging requirements," the conveyance should not be considered as part of the packaging. If the roll-on/roll-off industrial packaging meets the packaging requirements without including the conveyance, it would not be acceptable to consider the#

Page 2conveyance as part of the package. It is unlikely that you would need to take credit for the conveyance to meet the requirements for an industrial package. Therefore, the answer to your question is no, it is not acceptable to call the vehicle part of the packaging. I trust this satisfies your inquiry. Please contact us if we can be of any further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 SUBJECT: Clarification of Radioactive Material Packaging Washington Closure Hanford, LLC (WCH) is performing remediation and demolition activities of radioactive waste burial grounds and radioactive contaminated buildings. The remediation activities involve excavating contaminated soil and miscellaneous debris from burial grounds, underground pipes and concrete building foundations. Demolition activities involve decontamination and demolition of above ground facilities. This waste material is then packaged and shipped to a local disposal facility which is being managed by WCH for the government. The waste consists of soil and building debris that has been contaminated with radioactive material. The shipment method used to transport the radioactive contaminated material occurs in 18-yd3 roll-on/roll-off industrial packagings on vehicles specifically designed for these containers and dedicated for these shipments. When offered for transportation the roll-on/roll-off industrial packagings and vehicle lock together and become a single unit. 49 CFR 173.403 defines a radioactive material package as the packaging together with its radioactive contents as presented for transport. Radioactive material packaging is defined as the assembly of components necessary to ensure compliance with the packaging requirements of this subpart. It may consist of one or more receptacles, absorbent materials, spacing structures, thermal insulation, radiation shielding, and service equipment for filling, emptying, venting and pressure relief, and devices for cooling or absorbing mechanical shocks. The conveyance, tie-down system, and auxiliary equipment may sometimes be designated as part of the packaging. WCH would like DOT clarification regarding the following question: 1. When being offered for transportation, is it acceptable to call this a single radioactive material packaging? If you have any questions regarding this inquiry, please feel free to contact me at (509) 420-6581. Sincerely, 06/04/2010 · S+ev.ens; is /13~103 {(AlA. t t-o~q~ Robinson E Fillmore Transportation and Packaging Lead Washington Closure Hanford, LLC. 2620 Fermi Avenue Richland, WA 99354#