{"operation":"document","citation":"11-0296","title":"Washington Closure Hanford, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-05-01","effective_on":null,"summary":"11-0296 response to Washington Closure Hanford, LLC concerning 173.410.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0296.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0296.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0296","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110296.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMAY 0 1 2012\nMr. Robinson E. Fillmore\nTransportation and Packaging Lead\nWashington Closure Hanford, LLC\n2620 Fermi A venue\nRichland, W A 99354\nRef. No. 11-0296\nDear Mr. Fillmore:\nThis responds to your letter requesting clarification of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) applicable to the marking and labeling requirements of Class\n7 (Radioactive) material packages. Specifically, you ask whether a dedicated-use transport\nvehicle and its designed-for and securely attached 18 cubic yard roll-on/roll-off industrial\npackaging may be considered as one \"package\" as defined in § 173.403 of the HMR for\nthe purposes of marking and labeling.\nThe answer is no. As defined in § 173.410:\n•\nPackage means the packaging together with its radioactive contents as presented for\ntransport, and\n•\nPackaging means, for Class 7 (radioactive) materials, the assembly of components\nnecessary to ensure compliance with the packaging requirements of this subpart. It\nmay consist of one or more receptacles, absorbent materials, spacing structures,\nthermal insulation, radiation shielding, service equipment for filling, emptying,\nventing and pressure relief, and devices for cooling or absorbing mechanical shocks.\nThe conveyance, tie-down system, and auxiliary equipment may sometimes be\ndesignated as part of the packaging.\nIf consideration of the conveyance as part of the package is not \"necessary to ensure\ncompliance with the packaging requirements,\" the conveyance should not be considered as\npart of the packaging. If the roll-on/roll-off industrial packaging meets the packaging\nrequirements without including the conveyance, it would not be acceptable to consider the\n\n<<<PAGE 2>>>\n\nconveyance as part of the package. It is unlikely that you would need to take credit for the\nconveyance to meet the requirements for an industrial package. Therefore, the answer to\nyour question is no, it is not acceptable to call the vehicle part of the packaging.\nI trust this satisfies your inquiry. Please contact us if we can be of any further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nSUBJECT: Clarification of Radioactive Material Packaging\nWashington Closure Hanford, LLC (WCH) is performing remediation and demolition activities of\nradioactive waste burial grounds and radioactive contaminated buildings. The remediation\nactivities involve excavating contaminated soil and miscellaneous debris from burial grounds,\nunderground pipes and concrete building foundations. Demolition activities involve\ndecontamination and demolition of above ground facilities. This waste material is then packaged\nand shipped to a local disposal facility which is being managed by WCH for the government. The\nwaste consists of soil and building debris that has been contaminated with radioactive material.\nThe shipment method used to transport the radioactive contaminated material occurs in 18-yd3\nroll-on/roll-off industrial packagings on vehicles specifically designed for these containers and\ndedicated for these shipments. When offered for transportation the roll-on/roll-off industrial\npackagings and vehicle lock together and become a single unit.\n49 CFR 173.403 defines a radioactive material package as the packaging together with its\nradioactive contents as presented for transport.\nRadioactive material packaging is defined as the assembly of components necessary to ensure\ncompliance with the packaging requirements of this subpart. It may consist of one or more\nreceptacles, absorbent materials, spacing structures, thermal insulation, radiation shielding, and\nservice equipment for filling, emptying, venting and pressure relief, and devices for cooling or\nabsorbing mechanical shocks. The conveyance, tie-down system, and auxiliary equipment may\nsometimes be designated as part of the packaging. WCH would like DOT clarification\nregarding the following question:\n1. When being offered for transportation, is it acceptable to call this a single radioactive\nmaterial packaging?\nIf you have any questions regarding this inquiry, please feel free to contact me at (509) 420-6581.\nSincerely,\n06/04/2010\n· S+ev.ens;\nis /13~103\n{(AlA.\nt t-o~q~\nRobinson E Fillmore\nTransportation and Packaging Lead\nWashington Closure Hanford, LLC.\n2620 Fermi Avenue\nRichland, WA 99354","truncated":false,"body_characters":4650}