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RE: shipping violation?
The use of a large area wipe after performing DOT smears is only a
precautionary mechanism for package handling. I have no basis for using a
large-area masslin wipe for official DOT purposes and would not record a DOT
measurement with such a method.
Thanks for the reference.
Glen
glen.vickers@ucm.com
> -----Original Message-----
> From: William V Lipton [SMTP:liptonw@dteenergy.com]
> Sent: Thursday, June 08, 2000 9:58 AM
> To: Multiple recipients of list
> Subject: Re: shipping violation?
>
> 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??
> > > >
> > > >
> > >
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