Waste Management Federal Services — Hazardous Materials Safety Interpretation

Page 1U.S.Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration AUG 1 8 1998 Mr. J.G. Field Manager Engineering Rei. No. 98-0125 Waste Management Federal Services, Inc. • • 345 Hills Street Richland, WA 99352 Dear Mr. Field: This is in response to your letter of June 1, 1998, regarding the transport of low specific activity radioactive liquid (LSA) in a secured by a threaded cap or bolted flange. specification DOT 412 cargo tank that has a sump which has been Specifically, you asked if a threaded capped pipe or bolted flange may be used transporting a LSA liquid? to close an outlet on the sump of the tank when. - Yes, provided the sump is not the cargo : tank outlet used for normal loading or unloading of the tank. See §$ 178.345-1 "loading/unloading outlet" and 178.345-11. • I hope this satisfies your request. ! Delmer F. Billings Office Chief, Standards Development of Hazardous Materials Standards#

Page 2Waste Management Federal Services, Inc. 345 Hills Street Northwest Operations Phone 509.376.7055 Richland, WA 99352 509.372.1435 • June 1, 1998 WMNW-EPC-98-099 Mr. Edward Mazzullo Director of Office of Hazardous Materials Standards U.S. Department of Transportation 400 7th Street SW Washington, DC 20590 Dear Mr. Mazzullo: SHIPPING LOW SPECIFIC ACTIVITY LIQUID • Waste Management Federal Services, Inc., Northwest Operations question: "Is it permissible to transport radioactive low specific activity (LSA) liquid in a U.S. Department of Transportation (DOT) 412 cargo tank that has a sump consisting of a threaded cap or bolted flange, with either device securely closed?" Reference 173.427 (c) allows transport of LSA-I liquid in a DOT 412 cargo tank, but states that bottom outlets are not allowed. Reference 178-345-1, under the definition of "outlet," states that the following are not outlets: "A threaded opening securely closed during transportation with a threaded plug or a threaded cap a flanged opening securely closed during transportation with a bolted or welded blank flange... " Was it the intention of the regulations to allow a removable (non-welded) capped pipe or removable flange on the bottom of the tank when transporting LSA liquids? We are requesting a written interpretation for the U.S. Department of Energy, Richland Operations Office. Very truly yours, Engineeris acp RL - D. W. Claussen S7-55 WMH - D. L. McCall H11-11M/118Y WMNW - E. P. Clements H1-15 JGF File/LB Printed on Recycied Paper /#