FW: [ RadSafe ] Exempt Source Shipment to International Destination
mccormickl at hotmail.com
Wed Sep 3 14:44:54 CDT 2008
These would require IATA shipment as an Excepted Package, Limited Quantity of Radioactive Materials UN 2910 with the associated label. If shipping to yourself in France, make sure that you have permission in France to possess the materials.Luke McCormickUS Customs
> Subject: RE: [ RadSafe ] Exempt Source Shipment to International Destination> Date: Wed, 3 Sep 2008 09:06:01 -0500> From: joey-michael at uiowa.edu> To: hotgreenchile at gmail.com; cary.renquist at ezag.com; radsafe at radlab.nl; RADONPROFESSIONALS at LIST.UIOWA.EDU> CC: > > 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=49:18.104.22.168.22.214.171.124&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/> _______________________________________________> 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/
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