RE: shipping violation?

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

Bill,

Try not to overreact.  There is a world out there that isn't black and
white.  The regulator has to determine what they can and can't do with the
facts as they are made available.  You posed the apparent question as to why
the notification was retracted.  I presented a scenario that could fit the
provided statements and lead to that retraction. Apparently, your question
was rhetorical and you were not interested in what situations could lead to
a retraction.  I hate to waste my time, but someone else might find it
useful:

(1, 2 and 3): This has nothing to do with loopholes.  It has to do with
apparent violations and the related notificiation requirements.  If the
scenario is correct, the apparent violation that would be exceeding 300 cm2
-- which doesn't require notification.  The violation of exceeding 2.2
cpm/cm2 can apparently not be proven, hence would not require notification.
I never said it was right or wrong to exceed 300 cm2, I said many facilities
do it (primarily out of mistaken good intentions).  I'll also note that the
licensee DID report it, and it was retracted by the regulator.

(4) I guess I'm lost.   Back in the beginning,  =radsafe=  was created to
provide a forum for discussion among HP professionals.

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 10:07 AM
> To:	Multiple recipients of list
> Subject:	Re: shipping violation?
> 
> 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
> 
> 
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