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Re: A shipping query
Joel,
As was pointed out, 10CFR30.15 exempts you from NRC requirements, but
not from the DOT requirements of 49CFR. In this case, unless you can show
that your check sources are less than 0.002 uCi/gm, the material must be
shipped as radioactive material. If this material is an excepted quantity
(<0.001 times the Type A limit for each nuclide) it may be shipped as either
"limited quantity" or as "instrument or article". There is no difference in the
requirements for either classification. You may also be exempt from DOT
marking, labeling and shippping paper requirements as long as you meet the
requirements of 49CFR173.421 which are:
1. the material is in strong, tight, package,
2. the radiation level at any point on the exterior surface of the package does
not exceed 0.5 mrem/hr,
3. there is no removable contamination on the exterior surface of the
package,
4. the outside of the inner package, or the package itself marked be marked
"RADIOACTIVE",
5. the package does not contain more than 15 grams of U-235, and
6. the shipment is prepared as specified in 49CFR173.422 (the limited
quantity certification).
Also, if the material is a hazardous substance, you must meet all the other
requirements for shipping the material.
I hope this helps.
Paul J. Stoner
Senior Technical Specialist
ICN Worldwide Dosimetry Service
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