RE: shipping violation?

["Dunn, Wes" <WDunn@intiso.com>]

Bill, 

I think the implication (probably correct based on many facilities
practices) is that the entire container was wiped (2990 cm2), hence that is
the proper value to use in the determination (dpm/area).  Keeping in mind
that the 300 cm2 is intended to ensure a reasonable sampling, and not a
definitive perfect value (yes, even though it says "must".  One can argue
that wiping over 2990 cm2 has equal or greater efficiency),  that would be
seem to be reasonable grounds for a retraction.

Now, if they DID wipe 300 cm2, then there is clearly a violation.  You can't
average your sample over a greater area than sampled to reduce its value.

[BTW, I don't know who makes the call on retractions.]

Wes

Wesley M. Dunn, CHP
International Isotopes, Inc.
wdunn@intiso.com
Corporate Website http://www.intiso.com

> -----Original Message-----
> From:	William V Lipton [SMTP:liptonw@dteenergy.com]
> Sent:	Thursday, June 08, 2000 6:36 AM
> To:	Multiple recipients of list
> Subject:	shipping violation?
> 
> Please see that attached incident report and its "retraction."  This
> retraction may be premature.  The wipe of an arriving RAM shipment
> showed 4442 dpm, which was reported as above the shipping limit of 2.2
> dpm/cm2.  This now has been retracted on the basis that, since the
> surface area of the package is 2990 cm2, the average contamination level
> is less than the limit.
> 
> ********* WRONG******************************
> 
> Before making regulatory decisions please read the regulations:
> 
> 49 CFR 173.443 Contamination Control
> 
> " ... The level of non-fixed radioactive contamination  ... must be
> determined by either:  (1) Wiping an area of 300 square centimeters of
> the surface concerned ... or (2) Using other methods of assessment of
> equal or greater efficiency ..."
> 
> i.e., the contamination must be averaged over 300 cm2, NOT 2990 cm2.
> There could very well be a hot spot on the packge which was over the
> limit.
> 
> Who reviews these reports before they're published??
> 
> 
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