TECHNICAL AND REGULATORY CONSIDERATIONS IN USING FREIGHT CONTAINERS AS INDUSTRIAL PACKAGES Page: 2 of 10
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Proceedings of the 15th International Symposium on the
Packaging and Transportation of Radioactive Materials
October 21-26, 2007, Miami, Florida, USA
TECHNICAL AND REGULATORY CONSIDERATIONS IN USING FREIGHT
CONTAINERS AS INDUSTRIAL PACKAGES
Mark Hawk Erich Opperman Ronald B. Natali
Oak Ridge National Washington Savannah R. B. Natali Consulting, Inc.
Laboratory River Company
The United States (US) Department of Energy (DOE), Office of Environmental Management
(EM), is actively pursuing activities to reduce the radiological risk and clean up the
environmental legacy of the nation's nuclear weapons programs. EM has made significant
progress in recent years in the clean-up and closure of sites and is also focusing on longer-term
activities necessary for the completion of the clean-up program. The packaging and
transportation of contaminated demolition debris and low-level waste (LLW) materials in a safe
and cost-effective manner are essential in completing this mission. Toward this end, the US
Department of Transportation's (DOT) Final Rule on Hazardous Materials Regulation Final Rule
issued January 26, 2004, included a new provision authorizing the use of Freight Containers
(e.g., 20 and 40-foot ISO Containers) as Industrial Packages Type 1, 2, or 3 (IP-1, IP-2, and
IP-3). This paper will discuss the technical and regulatory considerations in using these newly
authorized and large packages for the packaging and transportation of LLW materials.
DOE and their contractors utilize freight containers for shipments of low-level radioactive waste
for disposal. Based on the classification of the material, numerous domestic shipments are
required to be placed in an IP-2 or an IP-3 packaging. For materials in bulk quantities or other
large materials, it is best to utilize bulk containers like freight containers, metal intermediate bulk
containers, or tank containers. This paper discusses the use of freight containers as authorized by
the US DOT regulations in the 49 Code of Federal Regulations (CFR) Part 173.
For many years, DOE EM, Office of Transportation, has sponsored a Packaging Management
Council (here forth known as "Council") that is open to all DOE contractors. The Council's role
is to address packaging and transportation issues that are common to the DOE sites. Over the last
7 or 8 years, the Council has focused on standardizing packaging associated with waste
shipments. Over the last few years, the preferred packaging of choice for waste disposal is the
freight container. However, since DOE contractors are having difficulty understanding what is
expected of them as offerors of these packagings to comply with the US DOT regulations, the
Council has taken on the goal of determining precisely what is required for the use and
documentation of freight containers to satisfy the regulations.
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Opperman, E; Mark Hawk, M & Ron Natali, R. TECHNICAL AND REGULATORY CONSIDERATIONS IN USING FREIGHT CONTAINERS AS INDUSTRIAL PACKAGES, article, October 16, 2007; [Aiken, South Carolina]. (digital.library.unt.edu/ark:/67531/metadc881538/m1/2/: accessed September 25, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.