[ RadSafe ] Export of exempt quantity Calibration sources?:

Dan W McCarn hotgreenchile at gmail.com
Tue Sep 7 20:15:32 CDT 2010

Hi Hermon:

The international (IAEA), IATA and USDOT / USNRC regulations are consistent
with each other for exempt sources.  See IAEA Publication 1225 - TS-R-1
(2005), IATA and 49 CFR 173.403. As long as the total of the
activity fractions in a shipment is less than one (1), there should be no
problems since that quantity is exempt from shipment labeling issues. If the
total of the activity fraction exceeds the value of 1, then labelling
(UN2910) is required. At least, that is my understanding as a geologist!

Understand that the term "exempt" has two meanings: 1) Exempt from
licensing; and 2) Exempt from labeling requiements. Sources may be exempt
from licensing, but if the aggregate of the activity fractions exceed the
value of 1, then the package is not exempt from labelling. They would then
require a UN2910 label.

I shipped both to and from France with no issues. I placed documentation
(receipts, P.O., and a declaration inside the package with the sources.
Attached is the document that I used minus the photographs of the sources.

I would recommend contacting the national authority to confirm that they
comply with the IAEA and IATA transport regulations.

This is what I wrote for the "Declaration of Exemption from DOT / IATA


Declaration of Exemption from DOT / IATA Labeling

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

The sources contained in this shipment represent 76% of the total
consignment limit for 49 CFR 173.403 as well as IATA 

US DOT PHMSA Interpretation Letter #07-0210, dated Jan 30, 2008 clearly
indicates that no labeling is required for check sources when a package is
less than the consignment limit (attached). This letter also directly
addresses transport of such sources on routine passenger airlines. 

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." 

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.

§173.433 - Requirements for determining basic radionuclide values, and for
the listing of radionuclides on shipping papers and labels. (Excerpt from

(7) The activity limit for an exempt consignment for mixtures of nuclides
may be determined as follows:
Exempt consignment activity limit for mixture:  
f(i) is the fraction of activity of nuclide i in the mixture; and
A(i) is the activity limit for exempt consignments for nuclide i.

Calculation: The exempt consignment limit for the mixture of the enclosed
check sources

Isotope	1/2 life	Date on Source	Days since Mfg	Labeled activity μCi
Current Activity μCi  1-Aug-09	Activity Limit μCi §173.436	Original
Fraction	Current Fraction 1-Aug-09
Ba133	10.5 y 01-Dec-07	609	1	0.896	27	0.037
Cd109	463 d	 01-Nov-07	639	1	0.384	27	0.037
Co57	272 d	 01-Dec-07	609	1	0.212	27	0.037
Co60	5.3 y	 01-Dec-07	609	1	0.804	2.7	0.370
Cs137	30 y	 01-Sep-08	334	0.1	0.098	0.27	0.370
Mn54	312 d	 01-Nov-07	639	1	0.242	27	0.037
Na22	2.6 y	 01-Dec-07	609	1	0.641	27	0.037
Zn65	244 d	 01-Oct-08	304	1	0.422	27	0.037
Sum of mixed activity fractions	0.963			0.764
A gamma survey of the shielded source container revealed the following
(Ludlum Model 19): 
Distance	Shielded	Unshielded
0 cm	150 μR/hr	1100 μR/hr
15 cm	23 μR/hr	110 μR/hr
25 cm	16 μR/hr	46 μR/hr
50 cm	11 μR/hr	18 μR/hr
100cm	10 μR/hr	12 μR/hr
Background 	9 μR/hr	

This very low level of radioactivity poses no regulatory or health concerns.

Based on these calculations and gamma measurements, the check / calibration
sources do not require DOT labeling as a Class 7 (Radioactive) material
because the sum of the mixed activity fraction is less than 1.  The sources
are always transported in a lead shield.

Also, note that these gamma check sources were purchased in the United
States by myself (Dan W McCarn) on 10 Dec 2007 and 17 Sep 2008 from: 

Spectrum Techniques, LLC, Attn: Larry Webb
106 Union Valley Road
Oak Ridge, TN 37830 USA
Tel: 1-865-482-9937
sales at spectrumtechniques.com 

The associated invoices are attached.  The second invoice (17 Sep 2008)
represents an exchange of two sources: 
1) A 1 μCi Cs-137 source (exempt quantity at the time of purchase) with a
0.1 μCi Cs-137 source, and 
2) A mixed 0.5 μCi Cs-137 & 1 μCi Zn-65 source with a 1 μCi Zn-65 source. 
The original sources were returned to the manufacturer, Spectrum Techniques.

I am moving my household effects back to the United States from France where
I have lived since October 2008.  These sources were acquired while I was
living in the USA in 2007 and 2008.

I hereby declare that these items are part of my personal household effects
purchased for calibration of my gamma spectrometer and check source for my
gamma survey meter.  They are not intended to be resold or transferred to
another party.


Dan W McCarn, Geologist
108 Sherwood Blvd
Los Alamos, NM 87544-3425
+1-505-672-2014 (Home - New Mexico)
+1-505-670-8123 (Mobile - New Mexico)
HotGreenChile at gmail.com (Private email) HotGreenChile at gmail dot com

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of HERMONRAO2 at aol.com
Sent: Tuesday, September 07, 2010 14:43
To: radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] Export of exempt quantity Calibration sources?:

Hi All:
Are there any NRC or DOT regulatory requirement that prohibit or  restrict
the shipment of exempt quantity calibration sources for typical gamma
spectrometric and or alpha spectrometric system to any educational
institution in foreign country say for example Saudi Arabia or Iraq or other
countries that may have special interest by US State department? If there
are  any 
regulatory requirements in this matter.. Could somebody direct me   where it

would be found in the CFR code? Thanks
Hermon Rao
Nuclear Technology Services, Inc.
635 Hembree Parkway
Roswell, GA 30076
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