{"operation":"document","citation":"13-0047","title":"Navarro Research and Engineering, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-05-09","effective_on":null,"summary":"13-0047 response to Navarro Research and Engineering, Inc. concerning 173.28.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0047.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0047.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0047","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130047.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMAY 092013\nMr. David Wilson\nPackaging and Transportation Project Manager\nNavarro Research and Engineering, Inc.\n669 Emory Valley Road\nOak Ridge, TN 3 7830\nReference No.: 13-0047\nDear Mr. Wilson:\nThis is in response to your February 8, 2013 letter and requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You reference a previous\nletter of interpretation, 11-03 02 issued to you by this office in November of 2011, and ask\nseveral questions concerning the reuse of Type B and fissile material packagings. Your\nquestions are paraphrased and answered as follows:\nQ 1. If packaging components are inspected and determined to require replacement in\naccordance with established acceptance criteria in the safety analysis report (SAR)\nsubmitted to the Nuclear Regulatory Commission (NRC), would these inspection and\nreplacement determinations be constructed as showing evidence of a reduction in integrity\nwhich would require the packaging to be reconditioned in accordance with § 173 .28( c )(2)?\nAl. The answer to your question is no. Routine inspections and replacements of packaging\ncomponents would not normally be considered to be evidence of a reduction in integrity\nwhich would require the packaging to be reconditioned in accordance with§ 173.28(c)(2).\nAs stated in§ 173.28(a), the reconditioning requirements apply only to packages which have\nsuffered damage which have reduced their structural integrity. Should an inspection reveal\nsufficient structural damage that reduces packaging integrity, then the reconditioning\nrequirements would apply.\nQ2. If containment is independent of the outer packaging (i.e. removable contaimnent\nvessel with separate closure device including any required gaskets), would the determination\nof a reduction in integrity of a containment system component also require the\nreconditioning of the protective outer packaging? Or is it permitted to recondition the\ncontainment system and outer packaging independently?\nA2. If it is determined that the reduction in packaging integrity is limited to the internal\ncontaimnent vessel and did not impact the outer packaging, reconditioning of the outer\npackaging would not be necessary.\n\n<<<PAGE 2>>>\n\nQ3. The requirements of§ 173.28( c)(2)(i) stipulate the removal of all former contents.\nWhat are the acceptable contamination limits that would satisfy this requirement? Would\nthe packaging be decontaminated to; less than or equal to the contamination levels specified\nin § 173.403, ensuring that the activity concentration and the total activity are less than or\nequal to the limits specified in § 173.403, less than or equal to the non-fixed external\ncontamination limits specified in§ 173.443, or less than or equal to the internal\ncontamination limits specified in§ 173.428(d)?\nA3. The requirement in§ 173.28(c)(2)(i) simply states, removal of all former contents.\nDecontamination is not required by this paragraph. However, if the packaging is to be\nshipped to another location to be repaired, it would need to meet the requirements of\n§ 173.443, or if shipped as \"Empty\", the requirements of§ 173.428.\nQ4. The requirements of§ 173.28(c)(2)(i) stipulate cleaning to original materials of\nconstruction. What extent of packaging disassembly would be required for packaging with\nintermediate cavities to satisfy this cleaning requirement? Or does this requirement only\napply to accessible surfaces?\nA4. This requirement only applies to those surfaces which would come in contact with the\ncontents and which would need cleaning to fully remove the contents.\nQS. For non-bulk Type Band Fissile Material packagings, what constitutes cushioning and\ncushioning material? Does the§ 173.28(c)(2)(iii) requirement for replacement of all\ncushioning and cushioning material impose the replacement of all impact-limiting materials\nof construction? Are elastomeric pads or spacers, which are used to avoid metal-to-metal\ncontact or to limit vibration, considered cushioning or cushioning material?\nAS. Cushioning material is not a defined term in the HMR. Without specific package\ndetails this office cannot determine what internal components may or may not be considered\ncushioning material. Generally speaking, cushioning material in non-bulk packages refers to\nmaterial that is not an integral component of the package that is added to absorb shocks\nnormally incident to transportation. Generally, elastomeric pads or spacers used as spacers\nbetween integral metal components would not considered to be cushioning or cushioning\nmaterial It is important to note that the requirement to replace cushioning and cushioning\nmaterial only applies to packages deemed to have damage which reduces its structural\nintegrity in accordance with§ 173.28.\nQ6. What markings applied by the reconditioner are required for non-bulk Type Band\nFissile Material packagings?\nA6. The requirement to mark reconditioned packaging in§ 173.28(c)(3) is limited to a\nperson who reconditions a packaging manufactured and marked under the provisions of\nsubpart L of part 178 of the HMR. As Type B and Fissile Materials are not packages\nmanufactured and marked under these provisions, no reconditioning mark is required.\nQ7. Based on the PHMSA response in interpretation 11-0302, a domestic reconditioning\nactivity would be imposed for non-bulk packagings that are internationally excluded from\nthe reuse and reconditioning requirements specified in chapter 6.1 of the United Nations\n\n<<<PAGE 3>>>\n\nModel Regulations. Are the PHMSA responses to Q 1-Q6 different for packages authorized\nin accordance with§§ 173.415(d), 173.416(b), 173.417(a)(l)(iii), and 173.417(b)(2)?\nA7. Packages offered in accordance with§§ 173.416(b), 173.417(a)(l)(iii), and\n173 .417(b )(2) are only authorized for export or import shipments and are contingent on the\npackage fulfilling the requirements of both the foreign competent authority certificate and\nthe U.S. Competent Authority revalidation, and all requirements of the certificates and\nrevalidations must be met in accordance with § 171.23(b )(11 )(ii). Packages offered in\naccordance with § 173 .415( d) must conform with requirements of the country of origin and\nthe International Atomic Energy Agency regulations applicable to Type A packagings. Our\nresponse to your previous interpretation request (11-0302), as well as this response, do not\nimpose any requirements beyond repairing a damaged package as needed to meet the\nrequirements applicable to it.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n£~i~~\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 4>>>\n\nNAVARRO\nResearch and Engineering, Inc.\nNAVARRO\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 1 of 6\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nAttn: PHH-10\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nADDITIONAL CLARIFICATION OF PACKAGING REUSE AND RECONDITIONING REQUIREMENTS\nGiven the the U.S. Department of Transportation (DOT), Pipeline and Hazardous Materials\nSafety Administration (PHMSA) response (Reference No.: 11-0302, dated April 2, 2012) to our\nprevious request for clarification (NRE-PE-11-0133, dated Nov. 2, 2011), we request additional\nclarification of the 49 CFR 173.28 provisions applicable to Type Band fissile material packagings,\nwhich: (1) are intended for reuse; (2) are considered non-bulk packagings as defined in\n49 CFR 171.8; and (3) meet the applicable requirements of 49 CFR 173, Subpart I, and have\nbeen evaluated, approved, and certified for use in accordance with 10 CFR Part 71. As described,\nthe subject packagings of this inquiry are authorized in accordance with the requirements of\n49 CFR 173.416(a), 49 CFR 173.417(a)(1)(ii), and 49 CFR 173.417(b)(1) as well as Type Band fissile\nmaterial packagings evaluated, approved, and certified by the U.S. Department of Energy in\naccordance with 49 CFR 173.7(d).\nBackground\nAs stated in 49 CFR 172.101(i), \"When packaging requirements are specified, they\nare in addition to the standard requirements for all packagings prescribed in § 173.24 of this\nsubchapter and any other applicable requirements in subparts A and B of part 173 of this\nsubchapter.\" The general design requirements in 49 CFR 173.410 establish that \"In addition\nto the requirements of subparts A and B of this part, each package used for the shipment of\nClass 7 (radioactive) materials must be designed so that-... \" Furthermore, it is recognized\nthat as specified in 49 CFR 173.401(a) the requirements in 49 CFR 173, Subpart I, are in\naddition to, not in place of, other requirements set forth in 49 CFR, Subchapter C, for Class 7\n(radioactive) materials and those of the U.S. Nuclear Regulatory Commission (NRC) delineated\nin 10 CFR 71.\n669 Emory Valley Rood, Oak Ridge, 1N 37830\n865-220-9650 • www.navarro-inc.com + 865-220-9651 Fax\n\n<<<PAGE 5>>>\n\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 2 of 6\nTitle 10 CFR 71.0(b} states that the requirements of 10 CFR 71 are in addition to, and\nnot in substitution for, other requirements. Also, 10 CFR 71.5 requires that the transportation\nof licensed material shall comply with the applicable requirements of the U.S. Department of\nTransportation regulations in 49 CFR parts 107, 171-180, and 390-397, appropriate to the\nmode of transport. Accordingly, the design, fabrication, assembly, testing, maintenance, repair,\nmodification, and use of the subject packagings is governed by the applicable NRC; DOT; and\nother Federal, State, and local regulations not preempted by the DOT.\nWith respect to the subject packagings, an application for package approval is prepared\nin accordance with the requirements of 10 CFR 71, Subpart D. NRC Regulatory Guide 7.9,\nStandard Format and Content of Part 71 Applications for Approval of Packages for Radioactive\nMaterial provides guidance on preparing the application for approval of Type 8 and fissile\nmaterial transportation packages. The application [hereafter referred to as a safety analysis\nreport (SAR}] is the principal document in which an applicant provides the information\nand bases for the NRC staff to use in determining whether a given package meets the\nrequirements of 10 CFR Part 71. Safety analysis reports that are prepared in accordance with\nthe standard format presented in NRC Regulatory Guide 7.9 will have sections, which establish\nthe fundamental requirements for the package operations as well as the acceptance tests and\nmaintenance program. Additionally, as specified in 10 CFR 71.37, the applicant shall describe\nthe quality assurance (QA} program for the design, fabrication, assembly, testing, maintenance,\nrepair, modification, and use of the proposed package.\nPackage operations, consistent with the package evaluation in the SAR, are routinely\nperformed in accordance with detailed, written site-specific procedures based on the Certificate\nof Compliance (CoC}, the package operations section of the SAR, and facility-specific operational\nrequirements. Acceptance tests and maintenance program activities are performed in\naccordance with the SAR provisions to ensure that the design requirements and the conditions\nof approval in the CoC are satisfied in addition to ensuring the integrity of the packaging\ncomponents with respect to the structural, thermal, containment, shielding, and criticality\nevaluations in the SAR. Furthermore, the subject packagings are fabricated, procured, and\nmaintained according to an approved QA program in accordance with 10 CFR 71, Subpart H.\nAs stated in 10 CFR 71.101(a}, this established QA program describes the quality assurance\nrequirements that apply to the design, purchase, fabrication, handling, shipping, storing,\ncleaning, assembly, inspection, testing, operation, maintenance, repair, and modification of\npackaging components that are important to safety.\nGuidance on the Determination of a Reduction in Integrity\nFor the subject packagings, routine inspections are performed to ensure that the\npackaging is in unimpaired physical condition, except for superficial defects, in accordance\nwith 49 CFR 173.47S(b} and 10 CFR 71.87(b} as well as required inspections to ensure that each\nclosure device of the packaging, including any required gasket, is properly installed, secured,\nand free of defects in accordance with 49 CFR 173.475(c} and 10 CFR 71.87(c). As required in\n\n<<<PAGE 6>>>\n\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 3 of 6\n10 CFR 71.91, records for the subject packagings are maintained, which verify: (1} that there\nare no significant defects in the packaging, as shipped; (2} the results of the quality control\nprovisions in 49 CFR 173.475 and routine determinations in 10 CFR 71.87; and (3} the conditions\nof the package approval. Reporting requirements for the subject packagings are specified in\n10 CFR 71.95, which include: (1) instances in which there is a significant reduction in the\neffectiveness of the subject packagings during use; or (2} details of any defects with safety\nsignificance in any of the subject packagings, after first use.\nThe package operations chapter of the SAR often permits incidental maintenance\nactivities including provisions for the routine replacement of damaged packaging components\nwith certified replacements during package loading, package unloading, and preparation of\nthe empty package for transport. In addition, the maintenance program often specifies\nroutine inspections with replacement requirements for deteriorated or damaged packaging\ncomponents in accordance with the SAR and as supplemented by the conditions of approval in\nthe CoC. Title 49 CFR 173.28(b}(1} states:\n(b) Reuse of non-bulk packaging. A non-bulk packaging used more than\nonce must conform to the following provisions and limitations:\n(1) A non-bulk packaging which, upon inspection, shows\nevidence of a reduction in integrity may not be reused\nunless it is reconditioned in accordance with paragraph (c)\nof this section.\nQl: If packaging components are inspected and determined to require replacement\nin accordance with established acceptance criteria in the SAR, would these inspection\nand replacement determinations be construed as showing \"evidence of a reduction in\nintegrity,\" which would require the packaging to be reconditioned in accordance with\n49 CFR 173.28(c}(2)?\nThe subject non-bulk packagings often incorporate design features for lifting,\ntie-down, impact limiting, thermal insulation, heat dissipation, radiation shielding, nuclear\ncriticality safety, and containment. The containment system may be integral to the packaging\nor it may be a separate container that is enclosed within a protective outer packaging, which\nmay be fabricated with intermediate cavities filled with impact-limiting, thermal-insulating,\nneutron-absorbing, or shielding materials and other engineering features. For packagings\nwith an integral containment boundary, which upon inspection shows evidence of a\nreduction in integrity, it seems apparent that based on the DOT PHMSA response\n(Reference No.: 11-0302) the packaging as a whole would be subject to the reconditioning\nrequirements in 49 CFR 173.28(c}(2}.\nQ2: If containment is independent of the outer packaging [i.e., removable containment\nvessel with separate closure device including any required gasket(s)], would the determination\nof a reduction in integrity of a containment system component also require the reconditioning\nof the protective outer packaging? Or, is it permitted to recondition the containment system\nand outer packaging independently?\n\n<<<PAGE 7>>>\n\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 4 of 6\nReconditioning of Non-Bulk Type B and Fissile Material Packagings\nAs required in 49 CFR 173.28(b), a non-bulk packaging, which upon inspection shows\nevidence of a reduction in integrity may not be reused unless it is reconditioned in accordance\nwith 49 CFR 173.28(c). For the subject packagings, the applicable reconditioning requirements\nare specified in 49 CFR173.28(c)(2), which states:\n(2) For the purpose of this subchapter, reconditioning of a non-bulk\npackaging other than a metal drum includes:\n(i) Removal of all former contents, external coatings and labels,\nand cleaning to the original materials of construction;\n(ii) Inspection after cleaning with rejection of packagings with\nvisible damage such as tears, creases or cracks, or damaged\nthreads or closures, or other significant defects;\n(iii) Replacement of all non-integral gaskets and closure devices\nwith new or refurbished parts, and cushioning and cushioning\nmaterials; and components including gaskets, closure devices\nand cushioning and cushioning material. (For a UN lHl plastic\ndrum, replacing a removable gasket or closure device with\nanother of the same design and material that provides\nequivalent performance does not constitute reconditioning); and\n(iv) Ensuring that the packagings are restored to a condition that\nconforms in all respects with the prescribed requirements of\nthis subchapter.\nQ3: The requirements of 49 CFR 173.28(c)(2)(i) stipulate the \"removal of all former\ncontents.\" What are the acceptable contamination limits that would satisfy this requirement?\nWould the packaging be decontaminated to:\n(1) less than or equal to the contamination levels (fixed plus removable)\nspecified in 49 CFR 173.403 (Contamination);\n(2) ensure that the activity concentration and the total activity are less\nthan or equal to the limits specified in 49 CFR 173.403 (Radioactive\nmaterial);\n(3) less than or equal to the non-fixed external contamination limits\nspecified in 49 CFR 173.443; or\n(4) less than or equal to the internal contamination limits specified in\n49 CFR 173.428(d)?\n\n<<<PAGE 8>>>\n\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 5 of 6\nAs stated earlier, the containment system for non-bulk Type Band Fissile Material\npackagings may be integral to the packaging or it may be a separate container that\nis enclosed within a protective outer packaging with intermediate cavities filled with\nimpact-limiting, thermal-insulating, neutron-absorbing, or shielding materials. While the\nrequirements of 49 CFR173.28(c)(2) are directly applicable to single-walled non-bulk packagings\n(other than a metal drum), without further clarification or guidance these requirements are not\nreadily extrapolated to the engineered features common to the subject non-bulk packagings.\nQ4: The requirements of 49 CFR 173.28(c)(2)(i) stipulate \"cleaning to the original\nmaterials of construction.\" What extent of packaging disassembly would be required for\npackagings with intermediate cavities to satisfy this cleaning requirement? Or, does this\nrequirement only apply to accessible surfaces?\nQS: For non-bulk Type Band Fissile Material packagings, what constitutes cushioning\nand cushioning material? Does the 49 CFR173.28(c)(2)(iii) requirement for replacement of all\ncushioning and cushioning material impose the replacement of all impact-limiting materials of\nconstruction? Are elastomeric pads or spacers, which are used to avoid metal-to-metal contact\nor to limit vibration, considered cushioning or cushioning material?\nMarkings Applied by the Reconditioner\nSince the subject packagings are not manufactured and marked under the provisions\nof 49 CFR 178, Subpart L-Non-bulk Performance-Oriented Packaging Standards, the first\nsentence of 49 CFR 173.28{c)(3) is not applicable. However, for the subject packagings that are\nreconditioned in accordance with 49 CFR 173.28(c)(2), marking requirements are imposed by\n49 CFR 173.28{c)(4) and the second sentence of 49 CFR 173.28{c)(3). Title 49 CFR 173.28(c)(3)\nand {4) state that:\n(3) A person who reconditions a packaging manufactured and\nmarked under the provisions of subpart L of part 178 of this\nsubchapter, shall mark that packaging as required by§ l78.503(c)\nand (d) of this subchapter. The marking is the certification of the\nreconditioner that the packaging conforms to the standard for\nwhich it is marked and that all functions performed by the\nreconditioner which are prescribed by this subchapter have\nbeen performed in compliance with this subchapter.\n(4) The markings applied by the reconditioner may be different\nfrom those applied by the manufacturer at the time of original\nmanufacture, but may not identify a greater performance\ncapability than that for which the original design type had been\ntested (for example, the reconditioner may mark a drum which\nwas originally marked as 1AI/Yl.8 as 1Al!Yl.2 or 1Al/Z2.0).\nQG: What \"markings applied by the reconditioner\" are required for non-bulk Type B and\nFissile Material packagings?\n\n<<<PAGE 9>>>\n\nNRE-PE-13-0136\nFebruary 8, 2013\nPage 6 of 6\nReconditioning of Other Non-Bulk Type B and Fissile Material Packagings\nWhile this request for clarification is limited to the applicability of 49 CFR 173.28 with\nrespect to the specified subset of Class 7 (radioactive) material packages, we recognize that\nfull consideration to the broader universe of packagings, which are subject to the requirements\nof 49 CFR 173, Subpart I, may be warranted. For example, non-bulk packages authorized\nin accordance with 49 CFR 173.415(d), 49 CFR 173.416(b), 49 CFR 173.417(a)(1)(iii), and\n49 CFR 173.417(b)(2), which meet the applicable requirements of the International Atomic\nEnergy Agency (IAEA), Regulations for the Safe Transport of Radioactive Material, 1996 Edition\n(Revised), No. TS-R-1 (ST-1, Revised), are excluded from international reconditioning activities\nas acknowledged in Chapter 6.1, \"Requirements for the Construction and Testing of Packages\"\nof the United Nations (UN) Recommendations on the Transport of Dangerous Goods, Model\nRegulations, sixteenth revised edition, Volumes I and II (2009). Although Chapter 6.1 of the\nUN Model Regulations includes requirements for reconditioning packagings, as stated in\n6.1.1.1, these requirements do not apply to packages containing radioactive material that\ncomply with the regulations of the IAEA.\nQ7: Based on the DOT PHMSA response (Reference No.: 11-0302), a domestic\nreconditioning activity would be imposed for non-bulk packagings that are internationally\nexcluded from the reuse and reconditioning requirements specified in Chapter 6.1 of the\nUN Model Regulations. Are the DOT responses to Q1-Q6 different for packages authorized\nin accordance with 49 CFR 173.415(d), 49 CFR 173.416(b), 49 CFR 173.417(a)(1)(iii), and\n49 CFR 173.417(b)(2)?\nIf you have any questions or need additional information, please feel free to contact me.\nRespectively submitted,\nDid tith\nDavid A. Wilson\nPackaging and Transportation Project Manager\nNavarro Research and Engineering, Inc.\n669 Emory Valley Road\nOak Ridge, TN 37830\nc: M. D. Waters, NRC/NMSS/SFST\nNavarro Project File\n\n<<<PAGE 10>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue SE\nWashington. DC 20590\nAPR 0 2 2012\nDavid Wilson\nPackaging and Transportation Project Manager\nNavarro Research and Engineering~ Inc.\n669 Emory Valley Road\nOak Ridge, TN 37830\nReference No.: 11-0302\nDear Mr. Wilson:\nThis is in response to your November 17, 2011letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the\nreuse and reconditioning provisions of§ 173.28. Specifically you ask if the reuse and\nreconditioning provisions of§ 173.28 are applicable to Type B(U), Type B(M), and fissile\nmaterial packagings.\nThe answer to your question is yes. Subpart I of part 173 describes the shippers general\nrequirements for Class 7 (radioactive) materials. General design requirements are\ndiscussed in § 173.410. The introductory text to § 173.410 states that each package used\nfor the shipment of Class 7 materials must be designed to the requirements of this section,\nas well as meet the requirements of subparts A and B of this part. The section you\nreference, § 173.28 is found in subpart B of part 173, and thus the reuse and reconditioning\nprovisions found in § 173.28 apply to shipments of Type B(U), Type B(M), or fissile\npackagings.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nP!:tHo·\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 11>>>\n\n),Ajdjb\n£3 t?3#Z-B\nRe.u~CJ\nII-Oc302\nNAVARRO\nResearch and Engineering, Inc.\nNRE-PE-11-0133\nNovember 17, 2011\nPage 1 of 1\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nAttn: PHH-10\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 2059Q-0001\nCLARIFICATION OF PACKAGING REUSE AND RECONDITIONING REQUIREMENTS\nIn support of transportation related activities associated with Class 7 (radioactive) materials\nunder the Hazardous Materials Regulations (49 CFR Parts 171-180), we request clarification of\nthe reuse and reconditioning provisions of 49 CFR 173.28 applicable to Type B(U), Type B(M),\nand fissile material packagings, which meet the applicable requirements of 49 CFR, Subpart I\nand have been evaluated, approved, and certified for use in accordance with 10 CFR Part 71.\nMore specifically, to what extent, if any, are the requirements of 49 CFR 173.28 applicable\nto Type B(U), Type B{M), and fissile material packagings?\nIf you have any questions or need additional information, please feel free to contact me.\nThank you for your assistance.\nRespectively submitted,\nDavid A. Wilson\nPackaging and Transportation Project Manager\nNavarro Research and Engineering, Inc.\n669 Emory Valley Road\nOak Ridge, TN 37830\n(865) 220-9650\nc: Navarro Project File\n669 Emory Valley Road, Oak Ridge, 1N 37830\n865-220-9650 • www .navarro-inc.com • 865-220-9651 Fax","truncated":false,"body_characters":25831}