[ RadSafe ] GN 71-1 Transport Container DOT Docs

[Ed Stroud]

Syd,
I can't speak for the other states, but here in Colorado the 2 big companies (you probably know who they are) have their Type A paperwork on file, if not at the local office, then on-line at their headquarters.  I know because I've looked at it myself.  Also, it's possible the inspectors noticed some type of modification to the container that could pose a safety issue. I once saw a container that had a home-made hinge and hasp attached to the lid. It was obvious, just from looking at it, that it wasn't safe and couldn't meet the Type A test requirements. 
-Ed    

>>> "Syd H. Levine" <syd.levine at mindspring.com> 2/4/2008 12:38 PM >>>
Since I happen to know our state regulators are on this list, let me say for 
the record that they are fine folks just trying to do a good job...

That being said, I am still a bit baffled this problem has arisen.  The 71-1 
is perhaps the most commonly used 3-5 Ci AmBe source in the oil patch.  How 
is it that our industry has used these transport containers on a daily basis 
for around a quarter of a century without a problem?  DOT must have 
historically been satisfied these shields met the 7A standard, or surely 
somebody would have acted before now.

Syd H. Levine
AnaLog Services, Inc.
Phone:  (270) 276-5671
Telefax:  (270) 276-5588
E-mail:  analog at logwell.com 
Web URL:  www.logwell.com 

----- Original Message ----- 
From: "Ed Stroud" <estroud at smtpgate.dphe.state.co.us>
To: "Syd H. Levine" <syd.levine at mindspring.com>; <radsafe at radlab.nl>
Sent: Monday, February 04, 2008 1:57 PM
Subject: Re: [ RadSafe ] GN 71-1 Transport Container DOT Docs


Syd,
The requirement (to have the Type A paperwork) originates with the USDOT 
regulations. See 49CFR173.415(a) which states, in part "Each offeror of a 
Specification 7A package must maintain on file for at least one year after 
the latest shipment, and shall provide to DOT on request, complete 
documentation on tests and engineering evaluation or comparative data 
showing that the construction methods, packaging design, and materials of 
construction comply wit that specification."  Your state inspectors are just 
trying to verify that the shipping container meets the USDOT requirements 
for shipping hazardous materials.

Ed Stroud, Health Physicist
Compliance Lead
Colorado Department of Public Health and Environment.

>>> "Syd H. Levine" <syd.levine at mindspring.com> 2/4/2008 9:28 AM >>>
Thanks for the replies on this, but I am not looking for the IAEA
Certificate of Competent Authority.  What is needed is the DOT 7A paperwork
on the Gulf Nuclear transport container used with the 71-1 three and five
Curie AmBe well logging neutron sources.

I think I have seen this document at one time or another, but cannot now
locate same.  Our state regulators are upset since nobody seems to have a
copy, yet apparently a copy must be with the shipping papers to be legal.

Scores of these transport containers are in daily use all over the US.  Has
anybody else run into this problem?

This is the cylindrical "pig" with an inner and outer steel wall and
containing either WEP or borated foam.  The older spherical version
contained paraffin, and it is my understanding these devices are no longer
permitted as 7A containers.

Thanks.

Syd H. Levine
AnaLog Services, Inc.
Phone:  (270) 276-5671
Telefax:  (270) 276-5588
E-mail:  analog at logwell.com 
Web URL:  www.logwell.com 

----- Original Message ----- 
From: "Syd H. Levine" <syd.levine at mindspring.com>
To: <radsafe at radlab.nl>
Sent: Friday, February 01, 2008 11:40 AM
Subject: [ RadSafe ] GN 71-1 Transport Container DOT Docs


>I am in urgent need of the DOT 7A certification document for the
>cylindrical transport container used with Gulf Nuclear 71-1 AmBe neutron
>sources.  Every logger with one of these transport containers is supposed
>to have a copy of said document, but I cannot locate a copy around here.
>
> I am not talking about the various source certificates, but rather the
> document that certifies the pig passes the DOT transport container
> requirements.  This is for the newer cylindrical version, not the older
> outlawed spherical version of the transport container.
>
> Thanks in advance for any help on this matter.
>
> Syd H. Levine
> AnaLog Services, Inc.
> Phone:  (270) 276-5671
> Telefax:  (270) 276-5588
> E-mail:  analog at logwell.com 
> Web URL:  www.logwell.com 
>
>
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