49CFR & IAEA ST-1, comments needed

[Lester Slaback <Lester.Slaback@NIST.GOV>]

To date I only see 5 comments on DoT's request for comments on the adoption
of the IAEA ST-1 rules into 49CFR.  There are a number of changes in ST-1
that should get folks interest.
1. All White I and Yellow II/III shipments require vehicle placarding
2. The use of ICRP QF reduces the A1/A2 values for neutron sources a factor
of 2
3.  The use of semi-infinite dose factors for evaluating a small-room
exposure for submersion radionuclides results in a factor of 10-100
conservatism for many of the nuclides.
4.  A prohibition of certain persons accompanying RAM shipments

There are also a number of very nice things in ST-1 that make shipments
more flexible, e.g., the change from a single 2 nCi/g criterion to an
activity AND a specific activity criteria.

There surely are more than 5 HPs who make RAM shipments in the U.S.
Comments sent to date are available at the www.dot.gov site.  Speak up now
or hold your peace.  My past experience is that DoT is quite responsive to
user's comments.
End of Friday's sermon.

Disclaimer:  the above are the personal musings of the author, and do not
represent any past, present, or future position of NIST, the U.S. government,
or anyone else who might think that they are in a position of authority. 
Lester Slaback, Jr.  [Lester.Slaback@NIST.GOV] 
NBSR Health Physics 
Center for Neutron Research 
NIST
100 Bureau Dr.  STOP 3543 
Gaithersburg, MD  20899-3543 
301 975-5810 voice
301 921-9847 fax
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