Hazwaste Packaging Consultants — 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 FEB 2 0 2014 Mr. Robert White Owner/CEO Hazwaste Packaging Consultants PO Box 209 Lenoir City, TN 37771-0209 Reference No. 13-0198 Dear Mr. White: This is in response to your September 19, 2013 letter requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to packaging. Your questions are paraphrased and answered below: Q 1: You state that in the absence of a reduced atmospheric pressure chamber, you internally pressurize a Type A packaging containing a radioactive material to 11.1 pounds per square inch (psi), close the air supply, and monitor the pressure gauge for a period of 5 minutes. You ask ifthe packaging is considered to have met the requirements in § 173.412(£) for reduction of ambient pressure if there is no loss in pressure for the 5 minute period. A1: The requirement in§ 173.412(£) for demonstrating whether a package can withstand reduction of ambient pressure to 25 kPa (3 .6 psi) is a design capability requirement. As required by§ 173.412(£), the containment system must retain its radioactive contents under the reduction of ambient pressure to 25kPa (3 .6 psi). Q2: You state that§ 173.410(£) references§§ 173.24, 173.24a, and 173.24b. You ask if §§ 173.24, 173.24a, and 173.24b all apply to both bulk and non-bulk packages. A2: Non-bulk packages would be subject to the packaging requirements in§§ 173.24 and 173.24a; bulk packages would be subject to the requirements of§§ 173.24 and 173.24b. Q3: You state that the packaging that is most commonly tested for Department of Energy (DOE) sites is a 96 cubic foot container filled to a gross weight of 11,000 pounds. You further state that the packaging can be designed and tested as an IP-1, IP-2, IP-2, 7 A Type A, or 7 A Type A, Fissile Qualified. You ask whether a 96 cubic foot container would be considered a bulk packaging. Additionally, you ask if this packaging is considered a non-bulk package, would it be permissible to test a single package to meet the vibration test as required by§ 178.608.#

Page 2A3: PHMSA defines a bulk packaging in § 171.8 as having a net mass greater than 400 kg (882 pounds). Since your packaging has a gross weight of 11,000 pounds it would be considered a bulk packaging under the HMR. A vibration test for a bulk packaging is not required under § 178.608. I hope this satisfies your request. Sincerely, ~7~~~--- T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3HAZWASTE PACKAGING CONSULTANTS 4nclrews ~ /73 , J.};o{f) .g 113 · ~ cf; September 19 2013 ?, 173. (2'-114. ' &173 .;;;J/h 7oeJ<cpqes I!J-o;Y;g U.S. DOT PHMSA Office of Hazareous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Dear Sirs, I have two (2) questions pertaining to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). QUESTION 1: Reference 49 CFR 173.412(f), Reduction of Ambient Pressure. In the absence of a reduced atmospheric pressure chamber, we internally pressurize a Packaging to 11.1 psig (14. 7 psi atmospheric pressure - 3.6 psi reduced ambient pressure = 11.1 psi), close the air supply, and monitor the Pressure Gauge for a period of 5-minutes. If there is no loss in pressure for the 5-minute period, the Packaging is considered to have passed the Test. Is this an acceptable method? QUESTION 2: Reference 49 CFR 173.410(f), Vibration a. 173.410(f) says "The package will be capable of withstanding the effects of any acceleration, vibration, or vibration resonance that may arise under normal conditions of transport without any deterioration in the effectiveness of the closing devices on the various receptacles or in the integrity of the package as a whole and without loosening or unintentionally releasing the nuts, bolts, or other securing devices even after repeated use. (see§§ 173.24, 173.24a, and 173.24b)." i. 173.24(f)(1) says, "Closures on packagings shall be so designed and closed that under conditions (including the effects of temperature, pressure, and vibration) normally incident to transportation, .... there is no release of material and the closure is leakproof. ii. 173.24a(5) says, "Vibration. Each non-bulk package must be capable of withstanding, without rupture or leakage, the vibration test procedure specified in 178.608 of this subchapter." iii. 173.24b does NOT require vibration testing 2a. Since 173.410(f) states: "see§§ 173.24, 173.24a, and 173.24b," are all Packagings subject to all three paragraphs? As I read it, 173.24 applies to all packagings, bulk and non-bulk; 172.24a applies to non- bulk packagings only; 173.24b applies to bulk packagings only. 2b. The Packaging that is most commonly tested for DOE Sites is 4' x 4' x 6' = nominal 96 cubic feet, with a filled gross weight of 11,000 lbs. (This size Packaging can be designed and tested as an IP-1, IP-2, IP- 3, 7A Type A, or 7A Type A, Fissile Qualified.) Is this a bulk packaging? If so, then I understand that the CFRs do not require a Vibration Test as specified in 178.608. Is this correct? 2c. IF a Vibration Test IS required, since there is no Vibration Test Machine that I know of large enough to handle three (3) of the above Packages simultaneously, because of both physical size and weight, is it permissible to use a single Package on the Vibration Table for the Test? Thank you for your help. Sincerely, Robert G. White Owner/CEO Hazwaste Packaging Consultants PO Box 209 Lenoir City, TN 37771-0209 (865)- 235-6555#