Tri-Cities Services, Inc. — Hazardous Materials Safety Interpretation

Page 1i of Transportatior J.S. Department 400 Seventh Street, S.W. Special Programs Research and Washington, D.C. 20590 Administration AUG 1 / 1999 Mr. Thomas C. Savage Manager, Transportation Operations DynCorp TriCities Services, Inc. P.O. Box 1400 Richland, WA 99352 Ref. No. 98-0129 Dear Mr. Savage: This responds to your letter regarding the transport of low specific activity (LSA) liquid in a specification DOT 412 cargo tank with a sump which has been securely closed by a threaded cap or bolted flange. Specifically, you asked if this type of arrangement is allowed when transporting LSA materials. The answer is yes, provided the sump is not the cargo tank outlet used for normal loading or unloading of the tank. See §§ 178.345-1 and 178.345-11. I hope this information satisfies your inquiry. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 178,345-1 980129#

Page 208/10/99 08:53 2509 376 8156 TRANSPORTATION 4002 DynCorp P.O. BOx 1400 Tri-Cities Services, Inc. Richlend, WA 99352 FAX (509) 372-1938 (509) 376-6068 June 3, 1998 Mr. Edward Mazzullo Director of Office of Hazardous Materials Standards U.S. Department of Transportation 400 7th Street SW Washington, D.C. 20590 Dear Mr. Mazzullo: SHIPPING LOW SPECIFIC ACTIVITY LIQUID DynCorp TriCities Services, Inc. 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 bolted flange 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.... DynCorp's interpretation of the regulations allows a securely closed, bolted blank flange on the bottom of the DOT 412 cargo tank when transporting LSA liquids, does DOT concur? We are requesting a written interpretation for the U.S. Department of Energy, Richland Operations Office. Very truly yours, Thomas (-Savage I. C. Savage, Manager Transportation Operations RL - D. W. Claussen S7-55 DYN - W. A Ferree G4-02 J. F. Woods G4-02 WNW - J. H. Portsmouth HI-14 ICS File/LB & 6002-082 011/563#