Packaging and Transportation Regulatory Inconsistencies and Challenges - 20485

This paper presents regulatory inconsistencies within and between various regulatory agencies. These inconsistencies relate to the packaging and transportation of radioactive materials typically encountered during decommissioning including mixed wastes that are required to be compliant with more than one regulatory agency during shipment. At least one possible solution is presented for consideration. The following four examples are presented: - Packaging discrepancies for radioactive material meeting the DOT definition of Radioactive LSA-I that also contain lead may be compliant when shipped unpackaged per Department of Transportation (DOT) rules in 173.427 paragraph C. However, since they contain lead, they are required to be shipped in a package per the Environmental Protection Agency (EPA) Hazardous Waste Manifest (HWM) instructions. - The difference between the units of measure used in 49 CFR Part 172.101 Appendix A and 40 CFR, Part 355, Appendices A and B. - The requirement for outer packaging for radioactive gauges meeting all other requirements of 49 CFR 173.424 and 173.425. - E-Manifesting EPA system difficult for waste materials containing both radioactive class 7 and PCBs. (authors)