[ RadSafe ] Exempt Source Shipment to International Destination

Wed Sep 3 09:06:01 CDT 2008

I'm thinking that you may have mixed NRC exempt with DOT exempt.  Exempt has different definitions depending on the regulatory agency.  As for international shipping, I have attempted something like this, and gave up in frustration.  Some couriers will not even carry radioactive material into certain countries.  The courier will let you know.  Good luck finding someone that knows about shipping dangerous goods internationally.  My experience was that the international shipping people would send me to the DG people and vice versa.  

If and when you accomplish this, please post back to the list what was required.  

BTW, I'm glad to see some operational health physics on the list. 

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Dan W McCarn
Sent: Wednesday, September 03, 2008 1:35 AM
To: 'Cary Renquist'; 'Radsafe'; RADONPROFESSIONALS at LIST.UIOWA.EDU
Subject: RE: [ RadSafe ] Exempt Source Shipment to International Destination

Hi Cary -

The contained quantities / isotopes are:

Isotope  μCi    Ci        Bq      Exempt Lim.
Ba-133    1   1.00E-06  3.70E+04   1.0E+06    10.8 years
Cd-109    1   1.00E-06  3.70E+04   1.0E+06    462  days
Cs-137    1   1.00E-06  3.70E+04   1.0E+04    30.2 years
Co-57     1   1.00E-06  3.70E+04   1.0E+06    272  days
Co-60     1   1.00E-06  3.70E+04   1.0E+05    5.27 years
Mn-54     1   1.00E-06  3.70E+04   1.0E+06    313  days
Na-22     1   1.00E-06  3.70E+04   1.0E+06    2.6  years
Unknown -     
Cs-137   0.5  5.00E-07  1.85E+04   1.0E+04    30.2 Years
Zn-65     1   1.00E-06  3.70E+04   1.0E+06    244 Days

Based on § 173.436   Exempt material activity concentrations and exempt
consignment activity limits for radionuclides, it seems that I'm over the
limit on Cs-137 for the exempt consignment limit even though these were sold
as exempt quantities two years ago.

Dan ii

Dan W. McCarn, Geologist; 3118 Pebble Lake Drive; Sugar Land, TX 77479; USA 
Home: +1-281-903-7667; Austria-cell:  +43-676-725-6622
HotGreenChile at gmail.com   UConcentrate at gmail.com

-----Original Message-----
From: Cary Renquist [mailto:cary.renquist at ezag.com] 
Sent: Tuesday, September 02, 2008 8:25 PM
To: Dan W McCarn; Radsafe; RADONPROFESSIONALS at LIST.UIOWA.EDU
Subject: RE: [ RadSafe ] Exempt Source Shipment to International Destination

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=a42c52a043bd518369
0631a3166d26cf&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

_______________________________________________
You are currently subscribed to the RadSafe mailing list

Before posting a message to RadSafe be sure to have read and understood the RadSafe rules. These can be found at: http://radlab.nl/radsafe/radsaferules.html

For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/