[ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

parthasarathy k s ksparth at yahoo.co.uk
Mon May 14 01:29:01 CDT 2007


Friends,

There was one instance of prosecution  of the staff  of a museum in London for exhibiting a geological sample   which caused an exposure rate above allowable  limit in the public domain . I do not have details of  the case. Any one in the radsafe list from the UK may be able to explain.

Regards
K.S.Parthasarathy

----- Original Message ----
From: Dan W McCarn <hotgreenchile at gmail.com>
To: Scott Davidson <bsdnuke at gmail.com>; edmond0033 <edmond0033 at comcast.net>
Cc: Don Jordan <DonJordan at ramservicesinc.com>; radsafe <radsafe at radlab.nl>
Sent: Monday, 14 May, 2007 4:58:53 AM
Subject: RE: [ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

Hello Group:

The days of uranium exploration and development are again back in the news.
In the "old" days prior to 9/11, I would carry samples of ore material in my
bags (up to about 1-2 kg of 1-10% U ore - in radiometric equilibrium with
progeny) while traveling internationally.  These samples are easily detected
at some distance from the bag. Are there any new rules, or is still OK to
carry non-processed rock samples (U ores).  Are there any issues with any
particular country or countries including the USA?

I always thought that rock samples were exempt; Is this still the case?

Has anyone had any difficulty traveling with radiation sensing equipment
such as gamma scintillation counters, etc. 

Best regards!

Dan ii

Dan W McCarn, Geologist
Albuquerque & Houston

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Scott Davidson
Sent: Sunday, May 13, 2007 11:11 AM
To: edmond0033
Cc: Don Jordan; radsafe
Subject: Re: [ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

With all respect due to any other commenter, would the source in question be
classified as radioactive under DOT if it did not pass both a concentration
*and* quantity (for the consignment) test under 49 CFR 173.436?

B. Scott Davidson, CHP, CSP


On 5/11/07, edmond0033 <edmond0033 at comcast.net> wrote:
>
> Depends upon what your Agreement State or NRC License allows you to do (if
> you have one)??
>
> Ed Baratta
>
> edmond0033 at comcast.net
> ----- Original Message -----
> From: "Don Jordan" <DonJordan at ramservicesinc.com>
> To: "radsafe" <radsafe at radlab.nl>
> Sent: Friday, May 11, 2007 8:41 PM
> Subject: Re: [ RadSafe ] Radioactive Material, Commerce, and DOT
> Regulations
>
>
> > Yes,
> >
> > The DoT regulations apply to "carriage on a public highway", even if you
> > are
> > carrying the check source in your pocket.
> >
> > Most of your examples would usually qualify as Limited Quantities and
> > would
> > be exempt from most packaging and documentation rule.  Some of your
> > examples
> > would be consumer goods and would be exempt from all the hazmat
> > regulations.
> >
> > Moisture density gauge owners and radiographers also require specific
> > radioactive materials licenses.  Interestingly,  radioagraphers have
> their
> > own set of NRC transport regulations.  They typically transport Type B
> > quantities, but do not have to have a 10 CFR Part 71 QA program.
> >
> > In a prior existence, however, I found one way to make all the DOT
> hazmat
> > regs. go away.  The key is public access.  If you can prevent public
> > access
> > during transport, you may be free from the rules.  We had to ship a
> nasty
> > Type B quantity 2 blocks, but my employer owned all the land & buildings
> > along the route and also owned a private, sworn police force who could
> > block
> > streets.  A call to DOT confirmed my reading of one of their more
> obscure
> > letters of interpretation that the hazmat reg.s wouldn't apply.  We
> still
> > hired a consultant to do the shipping & put it on a truck.  Cost was
> about
> > $1500, I think.
> >
> >  Don Jordan
> >
> > RAM Services, Inc.
> > 920-686-3889
> > ----- Original Message -----
> > From: "Mercado, Don" <don.mercado at lmco.com>
> > To: "radsafe" <radsafe at radlab.nl>
> > Sent: 11 May, 2007 5:05 PM
> > Subject: [ RadSafe ] Radioactive Material, Commerce, and DOT Regulations
> >
> >
> >> Happy Friday,
> >>
> >>
> >>
> >> I have a question about individuals carrying around radioactive
> material
> >> in their own or company vehicles. Does *everyone* carrying radioactive
> >> material on public roadways have to comply with all the DOT
> regulations?
> >> I'm thinking about people like the sales person who brought an ECD
> >> containing Ni-63 with him to install on one of our electron
> microscopes.
> >> Or the sales man who carries a check source to demonstrate the survey
> >> meters he's selling. The guy driving around with the moisture density
> >> gauge in his van or the source radiography operators? Someone who
> throws
> >> a generally licensed exit sign or a radium dial clock in their trunk.
> >>
> >>
> >>
> >> Are these people breaking the law? Looking at the definition of
> >> "commerce", I think they are.
> >>
> >>
> >>
> >> Comments please. Thanks in advance. Have a great weekend.
> >>
> >>
> >>
> >>
> >>
> >> Donald P. Mercado
> >>
> >> Radiation Safety Officer
> >>
> >> Explosives Safety Officer
> >>
> >> Lockheed Martin Space Systems Company
> >>
> >> O/9K-2S, B/157
> >>
> >> 1111 Lockheed Martin Way
> >>
> >> Sunnyvale, CA 94089
> >>
> >> Ph. (408) 742-0759
> >>
> >> Fx. (408) 756-0504
> >>
> >> Don.Mercado at lmco.com
> >>
> >>
> >>
> >> "Life is not a journey to the grave with the intention of arriving
> >> safely in a pretty and well preserved body, but rather to skid in
> >> broadside, thoroughly used up, totally worn out, and loudly proclaiming
> >> -- WOW!!! -- What a Ride!!!"
> >>
> >>
> >>
> >> _______________________________________________
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> >>
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> > the RadSafe rules. These can be found at:
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> >>
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> >
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>
>
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