Re: Waste Drum Sampling

["Charles Meyer" <cmeyer@brc1.tdh.state.tx.us>]

Date:          Sun, 9 Jun 96 15:34:23 -0500
Reply-to:      radsafe@romulus.ehs.uiuc.edu
From:          "Langsted, James" <james.langsted@rfets.gov>
To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Subject:       Waste Drum Sampling

To assure no free-standing liquids are contained in "dry" waste shipped to LLW
disposal, the State of Washington (Information Notice 95-1, July 31, 1995) has
recommended the drilling of a small hole to be sealed by a self-tapping screw,
rubber washer, and silicone or RTV.  My question is, does this significantly
affect the performance of the shipping container and place us in violation of
transportation regulations?

My own thoughts and questions...
_________________________________________________
Jim Langsted, CHP
M.H. Chew & Associates, Inc.
(303) 966-2542
james.langsted@rfets.gov
__________________________________________________

Mr. Langsted?,

If the package has been certified, say as a Type A package, with the 
screw, washer, and silicone already in place, then its a Type A 
package.  If part of the package integrety relies on the package 
being an IP I, II, or III, then you might have to demonstrate the 
package still meets those criteria.  For example, lets say you 
started with an IP II package and used that fact to demonstrate that 
the package meets the vibration test, then you put the screw et al in 
the package wall.  You might have to repeat the vibration test in 
order to comply with the general packaging standard.

Your question could be cussed and discussed at lenght on radsafe 
without resolution.  Your best bet is to query DOT in writing.  

                             Good Luck

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               Russ Meyer                            
               Internet: cmeyer@brc1.tdh.state.tx.us 
               tel: 512/834-6688                                                    
               fax: 512/834-6654
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