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I have a nagging question for someone with more experience
with DOT regs than I:
General Licensees routinely ship GL devices, such as ECDs and
Tritium exit signs, back to the distributor for replacement or disposal. The
packages are supposedly prepared for shipment under 49 CFR 173.424, Excepted
packages for radioactive instruments and articles. How are these general
licensees, who are not required or expected to have survey meters or liquid
scintillation counters available, supposed to survey the package to ensure that
non-fixed surface contamination is below the Table 11 limits? Is there a
(legal) way around this requirement?
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Clayton Bradt, CHP <raldrich@nysnet.net> phone: 518/457-1202 Assoc. Radiophysicist fax: 518/485-7406 NYS Dept. of Labor Radiological Health Unit Blg.12, Rm 169 State Office Campus Albany, NY 12240 *********************************************************************** |