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

Dustin G Miller DGMiller at enercon.com
Wed Jul 22 14:45:12 CDT 2009

NO, Henry, you are not correct.  You must be greater than the "Activity
concentration for exempt material" and the "Activity limit for exempt
consignment." in the table in § 173.436...not just one...for a shipment to
be required to be shipped under DOT Class 7 RAM regs.  The only time you
have to go beyond the .436 table is if the radionuclide is not listed in the
.436 table or the .435 A1/A2 table.

To argue semantics...yes it is radioactive material, but NO, it is not
regulated during domestic shipping as a Class 7 (Radioactive) Material.

Dustin G. Miller

-----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 3:00 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources -Yes


>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 
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.


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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