[ RadSafe ] Re: Exempt Quantity source shipments

roseb at gdls.com roseb at gdls.com
Thu Jul 23 14:08:02 CDT 2009


>It is not enough that the material is of exempt quantity, you MUST be 
licensed to transfer even exempt quantity, but not to receive it.

Per 10CFR30.18, the above statement might not be correct.

§ 30.18 Exempt quantities

>There are also limits as to how many eqempt quantities may be shipped in 
a single package (10).

What is the DOT, NRC, IATA, IMDG basis for this limitation?

If the sources do not meet the definition of Radioactive Material in 
49CFR173.403 due to the both activity concentration AND the total activity 
in the 
consignment NOT exceed the values specified in the table in 49CFR173.436, 
and are therefore not sufficiently radioactive to be subject to the HMR, 
why would there be a limitation on how many of the sources can be shipped 
under USDOT regs & jurisdiction?


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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