Re: shipping violation?

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

I'd have to disagree:

(1) The regulation is clear.  I do not see how you conclude that "the 300 cm2 is
intended to ensure a reasonable sampling."    That is addressed separately in
173.443(a)(1) "...Sufficient measurements must be taken in the most appropriate
locations to yield a representative assessment of the non-fixed contamination
levels..."  To try to create a loophole through "interpretation" is wrong.  If
you wipe an area larger than 300 cm2 you must still use 300 cm2 in the
denominator of  the "dpm/cm2" calculation  in determining regulatory compliance.

(2) To try to average out a hot spot over a large surface area is wrong.  The
level of contamination reported on that package could contaminate the facility
and could have left residual contamination in the transport vehicle.

(3)  Being  "many facilities practices..." doesn't make it correct.

(4)  It would be funny if it weren't so sad:  We're constantly trying to be the
victim, claiming that the media, public, ... doesn't trust us.  Yet, whenever
something goes wrong, our reaction seems to be to look for loopholes, rather
than address the cause.  Maybe there's a connection.

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

Bill Lipton
liptonw@dteenergy.com

"Dunn, Wes" wrote:

> 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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