LSA Packaging and Shipment By Rail

[Ben Poff <BPOFF@ITCRP.COM>]

Fellow Radsafers,

My questions involve shipping LSA material (11e.2 soils) via rail car
hoppers for disposal.

Question #1 - Does anyone know of certifications for rail cars that have
been performed to meet the "industrial package" requirements set forth in
49 CFR 173.411 and the tests required in 173.465 (or evaluated per
173.461(a)?  The rail industry is not very forthcoming with information on
this matter (and can be down right unfriendly).

Question #2 - Does anyone know how the "exclusive use" rules apply to
rail carriers?  My experience over the years has been that I consign the
loads as "exclusive use", and brief the rail carrier personnel on the
requirements (including getting the signature on the "instructions sheet"
provided with the manifest).  From that point on I think that the railroad
basically does whatever they want.  I know that they write their own
"manifest" for the shipment, but when I can actually get my hands on
receipt paperwork there is no mention of exclusive use controls for the
material.  I have taken the extra step of including my shipment papers with
each rail car, but I'm not convinced that things are happening as they
should.

Thanks (in advance) for your assistance.

Ben Poff
(505) 262-8948
bpoff@itcrp.com
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