[ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources -Yes orNo

[Kulp, Jeffrey B]

Mr. Rose,

	In order for a consignment to be considered radioactive materials for the purposes of shipment, both parameters must be met. This means that both the activity limit and the specific activity have to exceed the minimum levels before the consignment can be considered radioactive for shipment purposes. You can check with PHMSA if you wish. 

Jeff Kulp
Washington State University
Radiation Safety Office
Pullman, WA 99164-1302
(509) 335-8175


-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of roseb at gdls.com
Sent: Wednesday, July 22, 2009 12:00 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources -Yes orNo

Dan

>Cary appears to be correct! If so, I do not need to label anything. 

>Is this the consensus? Is this the consensus?

No.  The following is why I do not agree with Cary's view with respect to 
you intended package or consignment of sources.

49CFR173.403 Definitions
.
.
.

Exemption value means either an exempt material activity concentration or 
an exempt consignment activity limit listed in the table in § 173.436, or 
determined according to the procedures described in § 173.433, ***and used 
to
determine whether a given physically radioactive material is sufficiently 
radioactive to be subject to the HMR (see
definition of radioactive material)...***
.
.
.
Radioactive material means any material containing radionuclides ***where 
both the activity concentration //and// the total activity in the 
consignment exceed the values specified in the table in § 173.436*** or 
values derived according to the instructions in § 173.433.


Do you know the activity concentrations of the material sealed inside of 
the sources you are shipping? I.E. Ba-133 Sp.A = 1.6 Ci/g. In order to 
achieve the 2.7E-9 Ci/g exempt material activity concentration listed in 
173.436, the mass of the Ba-133, any other element or compound the Ba-133 
is mixed with, and the source capsule or substrate would require a mass of 
[1.0 uCi x (1 Ci/1E6 uCi)]/[2.7E-9 uCi/g]= 370 g (~13 oz weight).  Does 
the Ba-133 calibration source have a mass of 370 g?  If not, the activity 
concentration exceeds the value in the table in 49CFR173.436 and is 
therefore radioactive material (although it does not exceed the activity 
limit for an exempt consignment of Ba-133).  The other sources you intend 
to offer for transport / shipment will similarly exceed the value in the 
table in 49CFR173.436 and wil therefore also be radioactive material.

Henry

Boyd H. Rose, CM, CIH, CHMM
Sr. Safety and Environmental Engineering Specialist
Corporate Radiation Safety Officer
General Dynamics Land Systems
38500 Mound Road
Mail Zone 436-10-75
Sterling Heights , MI 48310-3269
Tel: 586 825 4503
Fax: 586 825 4015
E-mail: roseb at gdls.com


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