Lawrence Livermore National Laboratory — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Administration Materials Safety OCT 0 5 2015 Mr. Rod Coleman Lawrence Livermore National Laboratory 7000 East Avenue Livermore, CA 94550 Ref. No. 15-0077 Dear Mr. Coleman: This responds to your April 21, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-185). Specifically, you ask for clarification on the classification of the small capsules described in your request, which are each filled with .075 curies (Ci) of tritium gas and present a radioactive hazard as well as a flammable gas hazard (hydrogen). You also request guidance on how to obtain regulatory relief in order to transport this material by air in the non-Department of Transportation (DOT) specification packaging described in your request. In your request, you indicate that the shipment of the tritium-filled capsules meets the requirements of the HMR for transport as "UN 2910, Radioactive material, excepted package, limited quantity of material, Class 7." However, per the requirements of § 173.2a, the flammable gas would be the primary hazard class. Furthermore, given that § 173.306 states that "only packages of hazardous materials authorized aboard passenger- carrying aircraft may be transported as a limited quantity" and "UN1049, Hydrogen, compressed" is forbidden aboard passenger-carrying aircraft, your shipment cannot qualify for limited quantity exceptions and as such, the non-DOT specification packaging you wish to use is not authorized for air transport. Nevertheless, you state that air transport is needed to make your organization's project successful, and you believe the small amount of tritium gas contained within the capsules would not sustain a flame if an ignition source was present, as the total combustion energy if all the capsules were burned is only 4 joules (J). Therefore, you believe the flammable gas would not pose a safety risk during transportation, even when transported in the non-DOT specification packaging exhibited in your request. Based on the information you provided, it is the opinion of this Office that you should apply to PHMSA for permission to use the non-DOT specification packaging described in your request under the terms of a special permit. To apply, you must submit an application to the Associate Administrator for Hazardous Materials Safety in conformance with the requirements prescribed in 49 CFR Part 107, Subpart B. In your application, you must#

Page 2provide justification that the packaging design you are considering achieves a level of safety that is equal to or greater than that required under the HMR. You may obtain information on the special permit application process from our website at http://www.phmsa.dot.gov/hazmat/regs/sp-a, or by calling PHMSA's Approvals and Permits Division at (202) 366-4511. I hope this answers your inquiry. If you need additional assistance, please contact this Office at 202-366-8553. Sincerely, Ash ple Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Boothe §173.22 Suppers Rep. Dodd, Alice (PHMSA) §173.115 Class 2 Duresan From: 15-0077 Sent: Geller, Shelby CTR (PHMSA) To: Tuesday, April 21, 2015 3:44 PM Subject: Hazmat Interps FW: Request for interpretation or guidance on Tritium Shipment Attachments: LLNL Tritium Shipment interpretation request.pdf Dear Shante and Alice, Attached is a formal request for a letter of interpretation. Mr. Coleman spoke with Jordan Rivera, with guidance from Victoria Lehman. Thanks, Shelby From: Coleman, Rod [mailto:coleman6@lInl.gov] To: INFOCNTR (PHMSA) Sent: Friday, April 17, 2015 1:52 PM Cc: Williams, James (PHMSA) Subject: Request for interpretation or guidance on Tritium Shipment Office of Hazardous Material Safety, Attached is a description of a proposed shipment from Lawrence Livermore National Laboratory. I am asking for interpretation or guidance on the flammable gas classification on capsules filled with a small amount of tritium gas. Please let me know if you have any questions or concerns regarding this request. Thank you, Rod Coleman 925-424-4198#

Page 4To: Office of Pipeline and Hazardous Materials Safety Administration Office of Hazardous Material Safety From: Lawrence Livermore National Laboratory Rod Coleman 7000 East Ave coleman6@linl.gov Livermore, CA 94550 Subject: Guidance and Interpretation on Flammable Gas Classification of Capsules filled with Tritium Gas LLL will fill small glass and plastic capsules with tritium gas according to parameters listed in Table 1 below. The capsules are filled with tritium gas at a pressure up to 15 atmospheres (220 PSIA) and are no larger than 1.6 mm OD (Figure 1). We need to ship up to 10 capsules in one package to Rochester, NY by air freight. Each capsule contains up to .075 Ci of tritium gas. Each capsule will be individually captured in a stainless steel fixture and the 10 fixtures will be packed in a transportation vessel which is a non- DOT specification cylinder (Figure 2). The transportation vessel will be backfilled with argon at one atmosphere and capped prior to shipment. To make this project successful the material needs to arrive at the destination within one week after filling and requires air transport. Tritium gas is a radioactive material with a flammable gas subsidiary risk hazard (hydrogen). The shipment of these tritium filled capsules meet the requirements to ship as UN2910, Radioactive material, excepted package, limited quantity of material, class 7, however, the flammable gas would be the primary hazard class and is presenting a challenge for air transport in a non-DOT specification cylinder. Because of the small capsule volume, the pressure rise would be 2.2 psi if all 10 capsules were to break inside the 2 co transportation vessel. cubio centimeter pounds /square inch Based on the size of the capsules and the amount of tritium gas present, LLL believes this small volume of tritium gas would not sustain a flame if ignition source was present and therefore the flammable gas does not pose a safety concern during transportation. The total combustion energy if all capsules burned is only 4 joules. LLL is requesting an interpretation on the flammable gas classification based on amount of gas present in the capsules or guidance on obtaining relief to transport this material by air in the configuration described above.#

Page 5Capsule diameter, od 1.6| Capsule thickness Capsule radius, id 0.797 mm mm Capsule gas volume # of capsules in single shipment 3 10 capsules microns Composition 0.0021 Max pressure, atmospheres 100% Max pressure, PSIA 220.5 15 tritium PSIA atm Capsule gas volume at Standard Temperature & Pressure (STP) Total volume of all gas capsules in single shipment at STP 0.032 0.318 cC CC Activity of tritium 2.4 Activity per capsule Total activity of all capsules 753 75 mci/capsule Ci/cc mCi Proposed shipping vessel volume % T gas volume/argon volume 2 Pressure if all capsules break 15.9% cc Pressure rise 16.9 PSIA 2.2 PSIG Heat of enthalpy of hydrogen combustion Heat of combustion of capsules Total moles of tritium gas in shipment 0.0000130 286 kJ/mole 3.72 joules moles Table 1. Parameters used to evaluate shipment of 10 tritium filled capsules.#

Page 6Figure 1: Photo of single 1.6 mm capsule on penny.#

Page 7SS-4Y-TW-SC11 FART NUMBER COMMENTS Inciduel Egglie Iss S.V-S-VCR-39-8TB2 SS-S-VCR-1 -50 In DETAIL D SCALE 4 83124 1/10/2013 -SECTION A-A SCALE 1.7 SCALE U Plastic Shell Fill Vessel Short 0.s SHEET 1 CE 1 Figure 2. Drawing of proposed transportation vessel for ten, tritium-filled capsules. The vessel is based on Swagelok valve components.#