RE: shipping violation?

[Glen.Vickers@ucm.com]

This is indeed a quandry.  If the person wiped the entire package with one
smear, they'd have no way of knowing what the size of the contaminated area
was.  

We typically assess packages by performing 100 cm^2 smears, then we might
perform a large area masslin just to ensure the package is contamination
free.  If we found contamination on the large area smear, we wouldn't know
the size of the contaminated area, but we did perform "DOT" smears before we
did the large area wipe.

I would say the best practice would be to perform smears no greater than 300
cm^2 first, then perform a large area smear after the official DOT smears
have been taken.

Any other opinions or regulatory references?

Glen Vickers
glen.vickers@ucm.com

> -----Original Message-----
> From:	Dunn, Wes [SMTP:WDunn@intiso.com]
> Sent:	Thursday, June 08, 2000 8:21 AM
> To:	Multiple recipients of list
> Subject:	RE: shipping violation?
> 
> 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  This now has been retracted on the basis that, since the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??
> > 
> > 
> ************************************************************************
> The RADSAFE Frequently Asked Questions list, archives and subscription
> information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html


*********************************************************************************
This E-mail and any of its attachments may contain Unicom proprietary
information, which is privileged, confidential, or subject to copyright 
belonging to the Unicom family of Companies.  This E-mail is intended
solely for the use of the individual or entity to which it is addressed.  If
you are not the intended recipient of this E-mail, you are hereby notified
that any dissemination, distribution, copying, or action taken in relation
to the contents of and attachments to this E-mail is strictly prohibited
and may be unlawful.  If you have received this E-mail in error, please
notify the sender immediately and permanently delete the original and
any copy of this E-mail and any printout.  Thank You.
*********************************************************************************
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html