[ RadSafe ] GN 71-1 Transport Container DOT Docs

Ed Stroud estroud at smtpgate.dphe.state.co.us
Mon Feb 4 12:57:33 CST 2008


Syd,
The requirement (to have the Type A paperwork) originates with the USDOT regulations. See 49CFR173.415(a) which states, in part "Each offeror of a Specification 7A package must maintain on file for at least one year after the latest shipment, and shall provide to DOT on request, complete documentation on tests and engineering evaluation or comparative data showing that the construction methods, packaging design, and materials of construction comply wit that specification."  Your state inspectors are just trying to verify that the shipping container meets the USDOT requirements for shipping hazardous materials. 

Ed Stroud, Health Physicist
Compliance Lead
Colorado Department of Public Health and Environment.

>>> "Syd H. Levine" <syd.levine at mindspring.com> 2/4/2008 9:28 AM >>>
Thanks for the replies on this, but I am not looking for the IAEA 
Certificate of Competent Authority.  What is needed is the DOT 7A paperwork 
on the Gulf Nuclear transport container used with the 71-1 three and five 
Curie AmBe well logging neutron sources.

I think I have seen this document at one time or another, but cannot now 
locate same.  Our state regulators are upset since nobody seems to have a 
copy, yet apparently a copy must be with the shipping papers to be legal.

Scores of these transport containers are in daily use all over the US.  Has 
anybody else run into this problem?

This is the cylindrical "pig" with an inner and outer steel wall and 
containing either WEP or borated foam.  The older spherical version 
contained paraffin, and it is my understanding these devices are no longer 
permitted as 7A containers.

Thanks.

Syd H. Levine
AnaLog Services, Inc.
Phone:  (270) 276-5671
Telefax:  (270) 276-5588
E-mail:  analog at logwell.com 
Web URL:  www.logwell.com 

----- Original Message ----- 
From: "Syd H. Levine" <syd.levine at mindspring.com>
To: <radsafe at radlab.nl>
Sent: Friday, February 01, 2008 11:40 AM
Subject: [ RadSafe ] GN 71-1 Transport Container DOT Docs


>I am in urgent need of the DOT 7A certification document for the 
>cylindrical transport container used with Gulf Nuclear 71-1 AmBe neutron 
>sources.  Every logger with one of these transport containers is supposed 
>to have a copy of said document, but I cannot locate a copy around here.
>
> I am not talking about the various source certificates, but rather the 
> document that certifies the pig passes the DOT transport container 
> requirements.  This is for the newer cylindrical version, not the older 
> outlawed spherical version of the transport container.
>
> Thanks in advance for any help on this matter.
>
> Syd H. Levine
> AnaLog Services, Inc.
> Phone:  (270) 276-5671
> Telefax:  (270) 276-5588
> E-mail:  analog at logwell.com 
> Web URL:  www.logwell.com 
>
>
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