Re: Contaminated Scaffold Knuckles - Turkey Point

[William V Lipton <liptonw@DTEENERGY.COM>]

This must be used with caution.



The bad news:



1.  Read the regulations carefully:  Here are the key definitions from 49 CFR

173.403:



"Radioactive material" means any material having a SPECIFIC ACTIVIY [emphasis

mine] greater than  70 Bq per gram (0.002 microcurie per gram)(see definition of

"specific activity").



"Specific activity" of a radionuclide means the activity of the radionuclide per

unit mass of THAT RADIONUCLIDE [emphasis mine].  The specific activty of a

material in which the radionuclide is essentially uniformly distributed is the

activity per unit mass of the material.



The standard, "essentially uniformly distributed" is discussed in

NUREG-1608/RADREG-003, "Categorizing and Transporting Low Specific Activity

Materials and Surface Contaminated Objects."  It is a very rigorous standard.

(A less rigorous term, "distributed throughout," is used in some definitions.)

Distributed throughout gives you some leeway, but essentially evenly distributed

does not.  Although there is no quantitative definition of these terms,

NUREG-1608 guidance states that for the material to be considered essentially

evenly distributed, the specific activity among 0.1 m3 volumes should not vary

by more than a factor of 3.  Thus, materials with surface contamination cannot

be considered having their activity essentially evenly distributed.



That's the bad news.



The good news:



NUREG-1608 provides a threshold value for surface contamination, below which an

object may be shipped as nonradioactive.  This was apparently inadvertently

omitted from the regulations.  (see section 3.1.2):  The threshold is:  2200

dpm/100 cm2 beta-gamma and 220 dpm/100 cm2 alpha, averaged over 300 cm2.  (I

assume this limit applies to the total of removable and fixed contamination.)



Some final bad news:  If the shipment is carried out under ICAO (IATA)

regulations (eg, shipped by Fedex), the material must meet both the DOT limits,

above, and the new, ICAO radionuclide specific concentration and total quanitity

limits.  This is the only time I've seen the shipper required to meet both ICAO

and DOT regulations.



As you can see, the determination that an item which cannot be free released can

be shipped as nonradioactive is not simple.  I highly recommend that you fully

document all such shipments.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.



Bill Lipton

liptonw@dteenergy.com





Joe Heckman wrote:



> Rodney,

> For the purposes of transportation, materials with concentrations of less

> than 2 nCi/gram are not radioactive materials. When one determines the

> material to be shipped is less than 2 nCi/gram no other consideration with

> respect to RAM is required, therefore the LSA/SCO requirements do not apply.

> The LSA/SCO proper shipping names are used primarily (when possible) because

> exceptions to the packaging requirements are given for this material.

>

> Joseph Heckman, RRPT

> Site Radiation Safety Officer

> Containerized Waste Facility

> Envirocare of Utah, Inc.

> (801) 532-1330

> jheckman@envirocareutah.com <mailto:jheckman@envirocareutah.com>

>

> "Communications without intelligence is noise;

> Intelligence without communications is irrelevant."

> Gen. Alfred. M. Gray, USMC

>

> ************************************************************************

> You are currently subscribed to the Radsafe mailing list. To unsubscribe,

> send an e-mail to Majordomo@list.vanderbilt.edu  Put the text "unsubscribe

> radsafe" (no quote marks) in the body of the e-mail, with no subject line.



************************************************************************

You are currently subscribed to the Radsafe mailing list. To unsubscribe,

send an e-mail to Majordomo@list.vanderbilt.edu  Put the text "unsubscribe

radsafe" (no quote marks) in the body of the e-mail, with no subject line.