[ RadSafe ] RadSafe Digest, Vol 239, Issue 1

Thu Mar 11 08:25:15 CST 2010

Lieber Franz:

Just because a license exempt quantity of radionuclide in group of sources requires no license to have does not mean that they are exempt from transport requirements.  For instance, I have 6 sources.  If the aggregate activity exceeds the limit, then they fall under UN2910 rules.  Since they are all license exempt, I do not require a license to have them.

The IAEA publishes a document related to that rule - TS-R-1 (2009) which is exactly the same as the US DOT regulations described under 49 CFR 172.403 except that one calculation is in Ci and the other in Bq. The effective international regs are IATA 10.4.2.1.

This is a two part rule:

DEFINITION:
49CFR173.403: “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.” 

BASIS OF CALCULATION:
For the material to be considered “Radioactive Material”, the sum of the maximum permissible activity fractions may not exceed the value of 1.  If the value were to exceed “1”, then the package must be labeled as UN2910 as a Class 7 (Radioactive) material.  If the value is less than 1, no special packaging or labeling is required.  Please note that material IMPROPERLY labeled as Class 7 (Radioactive) with a UN2910 label that does not meet this specification may also be subject to fines.

§173.436 – Activity Limits for Exempt Consignment
Calculation of the sum of the mixed activity fractions is defined by 49 CFR 173.436 (activity limits for exempt consignment).  Cs-137 = 0.27 microcurie (μCi); Co-60 = 2.7 microcurie; and Ba-133, Cd-109, Co-57, Mn-54, Na-22, Zn-65 = 27 microcurie.

Note that the license exempt quantity of Cs-137 is 0.1 microcurie whereas the transport exempt quantity is 0.27 microcurie.  This means that one might require a license to have a 0.2 microcurie source but it would be exempt from transport requirements

Glückauf!

Dan ii

--
Dan W McCarn, Geologist
2867 A Fuego Sagrado
Santa Fe, NM 87505
+1-505-310-3922 (Mobile – New Mexico)
HotGreenChile at gmail.com (Private email)

-----Original Message-----
From: Franz Schönhofer [mailto:franz.schoenhofer at chello.at] 
Sent: Wednesday, March 10, 2010 14:20
To: 'Dan W McCarn'; 'Brennan, Mike (DOH)'; radsafe at health.phys.iit.edu
Cc: Ken.Peterson at us.fincantieri.com
Subject: AW: [ RadSafe ] RadSafe Digest, Vol 239, Issue 1

Dan, 

Sorry that we never met in Vienna. I am more than sure that we would have
had a lot of fruitful discusssions for hours and hours to go on! I actually
wonder why you never have contacted me though my telephone number was always
given in my messsges to RADSAFE. 

Though I agree with most of your contributions I cannot agree with your
latest one. What are your exempt check sources, why should they be treated
in any way separately?? They are exempt - ok, no need to  control them or
restrict them. Mineral waters with extremely high Radium content - should
they be controlled at the border? This is close to be ridiculous.

Best regards and wishes,

Franz

Franz Schoenhofer, PhD
MinRat i.R.
Habicherg. 31/7
A-1160 Wien/Vienna
AUSTRIA

-----Ursprüngliche Nachricht-----
Von: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] Im Auftrag von Dan W McCarn
Gesendet: Mittwoch, 10. März 2010 20:13
An: 'Brennan, Mike (DOH)'; radsafe at health.phys.iit.edu
Cc: Ken.Peterson at us.fincantieri.com
Betreff: Re: [ RadSafe ] RadSafe Digest, Vol 239, Issue 1

Dear Ken:

I agree with Mike on this one.  Also remember that the shoe bomber came from
overseas... Since we are so interconnected, it is the obligation of all
governments to help assure flight safety at all levels, and many regulations
are international e.g. IATA transport regs.  This means that a bag checked
at some obscure airport should have the same scrutiny as a bag checked (or
brought onboard) at a major airport.  This provides consistency
internationally.  

http://www.iata.org/index.htm 

I offer as an example my exempt check sources that I occasionally travel
with: I provide this following statement along with a calculation to
demonstrate compliance and a few telephone numbers to NRC and the
manufacturer of the sealed sources.

"The enclosed check / calibration sources are not considered radioactive
material for transport because they do not meet the test for DOT
"Radioactive Material" as defined in 49 CFR 173.403 as well as IATA
10.4.2.1"

Otherwise I would have to ship them under UN2910 regulations including
labeling.  If anyone would like a copy of the statement that I enclose in my
baggage, I'd be delighted to provide it!

Air travel is a privilege, not a right.  The same is true for a drivers
license.

Personally, I don't mind being selected-out for close inspection; I always
tell the folks conducting the inspection with a smile that "You mean I'm
special!?" and almost always get a smile back.  A couple of times it was to
clarify objects in my baggage, almost always my Ludlum Model 19, and once, a
saddle for my horse!  The smell of the horse on the saddle may have caused a
false positive from the sniffing dogs and it had an unusual shape.

Where have I been selected for close inspection? The USA, Germany, Belarus,
Kazakhstan and China so far.  That seems pretty international to me!  And,
as often as I have flown into and out of Schwechat in Vienna (30-40 times),
I've never been searched. It must be my Austrian accent!

Dan ii

--
Dan W McCarn, Geologist
2867 A Fuego Sagrado
Santa Fe, NM 87505
+1-505-310-3922 (Mobile - New Mexico)
HotGreenChile at gmail.com (Private email)

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Brennan, Mike
(DOH)
Sent: Wednesday, March 10, 2010 10:58
To: radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] RadSafe Digest, Vol 239, Issue 1

Hi, Ken.

If you have to pay money, it isn't a right (one of the things that
distinguish "rights" from "privileges" is that rights are paid for
collectively rather than individually, and the coin is often much more
valuable than money).  It is a clear fact that traveling by commercial
air is handled as a contractual agreement between the carrier and the
(intended) passenger, subject to non-trivial levels of regulation
designed to serve a number of agendas.  At the moment, many of those
regulations are aimed at preventing people from bringing things aboard
planes that would let them threaten the plane or passengers.  I think
there are a lot of things that could be done to make the system more
effective (a national ID system, for example, with biometric
verification, for example), but that is another discussion.  

As for frisking little old ladies: Your objection shows a lack of
imagination.  Do you think that someone who is willing to bring down an
airplane would balk at using an elderly person as their delivery system?
And if you don't think that senior citizens can hate strongly enough (or
can be brought to that point by manipulation) to use their own deaths to
make a point, you see a different world than I do.  As for the "only on
international flights" argument, I invite you to refresh your memory as
to where the 9/11 planes took off from, and where they were going.  

The system could be much better, and more efficient and cost effective.
If used properly the new scanners can actually be a step in the right
direction.  I find it annoying that the puritanical body taboos of the
few are given such deference, and that they often try to co-opt
completely spurious radiation health arguments.

I agree with you that terrorists follow the best risk-to-return ratio.
For the last eight years the best ratio has been roadside bombs in Iraq.
As the number of Americans available in that venue decreases, it is
entirely possible some groups will try for more difficult targets, such
as airplanes.  It is a fair investment to make their job more difficult,
and I think the new scanners are a step in the right direction, though
years late.  And, if it is the only step, we are in trouble.    

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Peterson, Ken
Sent: Tuesday, March 09, 2010 2:06 PM
To: radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] RadSafe Digest, Vol 239, Issue 1

Mike,

I take exception to point (1).  Air travel is not a privilege; if you
can pay the fare and don't have a bombmaking background - you have every
right to fly - and not be hassled in the process.  I fly 75K miles per
year, and I resent tax dollars wasted in creating bigger bureaucracies
and money pits like the TSA who give authority over me to those who
don't deserve or earn it.  

I believe frisking 80 year old ladies before they get on the Burbank to
Phoenix flight is stupid and futile.  I am tired of countless delays,
removing shoes, packing my nail clippers, arriving at the airport two
hours before a flight to stand in endless security lines.  I welcome
these scanners if they are unobtrusive and one can briskly walk through
them without delay.  

While I think international flights are another matter, for domestic
travel, arming the pilots and armoring the cockpit door is all the
security we need.  Once the goal of using the plane as a guided missile
is thwarted, and the only possible result is killing 100 passengers and
a dozen people on the ground instead of killing thousands and destroying
visible landmarks - the risk to reward ratio goes way down, and the
terrorists will look elsewhere for targets. 

Ken Peterson
**********************
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