Re: shipping violation?

[William V Lipton <liptonw@dteenergy.com>]

I suggest reading NRC Information Notice No. 85-46, "Clarification of Several Aspects
of Removable Radioactive Surface Contamination Limits for Transport Packages."
Attachment 1 addresses "averaging of wipe samples" - You can average over 300 cm2,
NOT the entire wipe area if it is larger than 300 cm2; while attachment 2 addresses
"use of higher efficiency wipe samples" - A large area smear is NOT a higher
efficiency wipe sample, contrary to a previous comment.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

Glen.Vickers@ucm.com wrote:

> 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

************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html