{"operation":"document","citation":"13-0198","title":"Hazwaste Packaging Consultants — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-02-20","effective_on":null,"summary":"13-0198 response to Hazwaste Packaging Consultants concerning 173.24, 173.24a, 173.24b, 173.412.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0198","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130198.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\nFEB 2 0 2014\nMr. Robert White\nOwner/CEO\nHazwaste Packaging Consultants\nPO Box 209\nLenoir City, TN 37771-0209\nReference No. 13-0198\nDear Mr. White:\nThis is in response to your September 19, 2013 letter requesting clarification ofthe Hazardous\nMaterials Regulations (HMR; 49 CPR Parts 171-180) applicable to packaging. Your questions\nare paraphrased and answered below:\nQ 1: You state that in the absence of a reduced atmospheric pressure chamber, you internally\npressurize a Type A packaging containing a radioactive material to 11.1 pounds per\nsquare inch (psi), close the air supply, and monitor the pressure gauge for a period of 5\nminutes. You ask ifthe packaging is considered to have met the requirements in\n§ 173.412(£) for reduction of ambient pressure if there is no loss in pressure for the 5\nminute period.\nA1: The requirement in§ 173.412(£) for demonstrating whether a package can withstand\nreduction of ambient pressure to 25 kPa (3 .6 psi) is a design capability requirement. As\nrequired by§ 173.412(£), the containment system must retain its radioactive contents\nunder the reduction of ambient pressure to 25kPa (3 .6 psi).\nQ2: You state that§ 173.410(£) references§§ 173.24, 173.24a, and 173.24b. You ask if\n§§ 173.24, 173.24a, and 173.24b all apply to both bulk and non-bulk packages.\nA2: Non-bulk packages would be subject to the packaging requirements in§§ 173.24 and\n173.24a; bulk packages would be subject to the requirements of§§ 173.24 and 173.24b.\nQ3: You state that the packaging that is most commonly tested for Department of Energy\n(DOE) sites is a 96 cubic foot container filled to a gross weight of 11,000 pounds. You\nfurther state that the packaging can be designed and tested as an IP-1, IP-2, IP-2, 7 A\nType A, or 7 A Type A, Fissile Qualified. You ask whether a 96 cubic foot container\nwould be considered a bulk packaging. Additionally, you ask if this packaging is\nconsidered a non-bulk package, would it be permissible to test a single package to meet\nthe vibration test as required by§ 178.608.\n\n<<<PAGE 2>>>\n\nA3: PHMSA defines a bulk packaging in § 171.8 as having a net mass greater than 400 kg\n(882 pounds). Since your packaging has a gross weight of 11,000 pounds it would be\nconsidered a bulk packaging under the HMR. A vibration test for a bulk packaging is\nnot required under § 178.608.\nI hope this satisfies your request.\nSincerely,\n~7~~~---\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nHAZWASTE\nPACKAGING\nCONSULTANTS\n4nclrews\n~ /73 , J.};o{f)\n.g 113 · ~ cf; September 19 2013\n?, 173. (2'-114. '\n&173 .;;;J/h\n7oeJ<cpqes\nI!J-o;Y;g\nU.S. DOT\nPHMSA Office of Hazareous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nDear Sirs,\nI have two (2) questions pertaining to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nQUESTION 1:\nReference 49 CFR 173.412(f), Reduction of Ambient Pressure.\nIn the absence of a reduced atmospheric pressure chamber, we internally pressurize a Packaging to\n11.1 psig (14. 7 psi atmospheric pressure - 3.6 psi reduced ambient pressure = 11.1 psi), close the air\nsupply, and monitor the Pressure Gauge for a period of 5-minutes. If there is no loss in pressure for the\n5-minute period, the Packaging is considered to have passed the Test. Is this an acceptable method?\nQUESTION 2:\nReference 49 CFR 173.410(f), Vibration\na. 173.410(f) says \"The package will be capable of withstanding the effects of any acceleration,\nvibration, or vibration resonance that may arise under normal conditions of transport without any\ndeterioration in the effectiveness of the closing devices on the various receptacles or in the integrity\nof the package as a whole and without loosening or unintentionally releasing the nuts, bolts, or other\nsecuring devices even after repeated use. (see§§ 173.24, 173.24a, and 173.24b).\"\ni. 173.24(f)(1) says, \"Closures on packagings shall be so designed and closed that under\nconditions (including the effects of temperature, pressure, and vibration) normally incident to\ntransportation, .... there is no release of material and the closure is leakproof.\nii. 173.24a(5) says, \"Vibration. Each non-bulk package must be capable of withstanding, without\nrupture or leakage, the vibration test procedure specified in 178.608 of this subchapter.\"\niii. 173.24b does NOT require vibration testing\n2a. Since 173.410(f) states: \"see§§ 173.24, 173.24a, and 173.24b,\" are all Packagings subject to all three\nparagraphs? As I read it, 173.24 applies to all packagings, bulk and non-bulk; 172.24a applies to non-\nbulk packagings only; 173.24b applies to bulk packagings only.\n2b. The Packaging that is most commonly tested for DOE Sites is 4' x 4' x 6' = nominal 96 cubic feet, with a\nfilled gross weight of 11,000 lbs. (This size Packaging can be designed and tested as an IP-1, IP-2, IP-\n3, 7A Type A, or 7A Type A, Fissile Qualified.) Is this a bulk packaging? If so, then I understand that the\nCFRs do not require a Vibration Test as specified in 178.608. Is this correct?\n2c. IF a Vibration Test IS required, since there is no Vibration Test Machine that I know of large enough to\nhandle three (3) of the above Packages simultaneously, because of both physical size and weight, is it\npermissible to use a single Package on the Vibration Table for the Test?\nThank you for your help.\nSincerely,\nRobert G. White\nOwner/CEO\nHazwaste Packaging Consultants\nPO Box 209\nLenoir City, TN 37771-0209\n(865)- 235-6555","truncated":false,"body_characters":5669}