[ RadSafe ] Exempt Source Shipment to International Destination

[Cary Renquist]

If you need to ship them UN 2910, then they probably don't meet the exception values for possession...

It has been a while since I have delved into this subject, so follow-up with your own research.

Be aware that "NRC exempt" does not equal "international exempt"...  In general, the NRC source limits are higher and allow for higher "possession limits", however the "international exempt" sources include a greater breadth of nuclides, e.g. include Am-241. (there are also a few notable nuclides that are higher than the NRC limits e.g. Co-60).

EU Directives:
Energy - Nuclear Issues 
<http://ec.europa.eu/energy/nuclear/radioprotection/legislation_en.htm>
   96/29/EURATOM 
   98/C133/03 (sort of a 96/29 reg guide)

Generally, non-US exempt quantity limits follow the IAEA exemption limits.
In the US, the primary reference that one might have on hand is 49 cfr: 49 CFR § 173.436.

49 CFR § 173.436   Exempt material activity concentrations and exempt consignment activity limits for radionuclides.: 
<http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=a42c52a043bd5183690631a3166d26cf&rgn=div8&view=text&node=49:2.1.1.3.8.9.25.25&idno=49>

The actual exemption list is in 96/29 Annex I Table A.

France (and other EU States) can have regs that allow higher exemption activities for devices/sealed sources, but they need to be of a design approved by the State, meet dose rate criteria (less than 1 uSv/h at 0.1 m), have conditions for disposal specified, etc.  

Basically it boils down to unless the sources are registered in France for "exempt distribution" then they must be less than the 96/29 exemption values.  
>From 96/29: "The values laid down in Table A apply to the total inventory of radioactive substances held by a person or undertaking as part of a specific practice at any point in time".  So, you are essentially under a sum of the ratios <= 1 situation i.e. each source has to be less than the exemption quantity.

Good luck,
Cary

---
Cary Renquist
RSO, Eckert & Ziegler Isotope Products
Office: +1 661-309-1033
cary.renquist at ezag.com

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Dan W McCarn
Sent: Tuesday, 02 September, 2008 14:57
To: 'Radsafe'; RADONPROFESSIONALS at LIST.UIOWA.EDU
Cc: sales at spectrumtechniques.com
Subject: [ RadSafe ] Exempt Source Shipment to International Destination

Dan W. McCarn, Geologist; 3118 Pebble Lake Drive; Sugar Land, TX 77479; USA 

Home: +1-281-903-7667; Austria-cell:  +43-676-725-6622

 <mailto:HotGreenChile at gmail.com> HotGreenChile at gmail.com
UConcentrate at gmail.com

 

Hello Group:

 

I have a Spectrum Techniques Model RSS 8 Gamma Source Set (Exempt Sources)
that I would like to ship to my new residence in France.  In a lead source
shield, the sources measure 45 microR/hr at 6 inches and about 75 microR/hr
on the surface of my Storm King case, well within the limits of UN-2910
regulations.

 

Do I need to obtain an export license for these exempt quantities from
Spectrum Techniques?  If not, what, if any, documentation do I need to
provide along with the shipment? 

 

Does the UN-2910 label need to appear in French as well?

 

Thanks!

 

Dan ii
Dan W McCarn