RE: Surface Contaminated Objects and release limits

["Wesley" <wesvanpelt@ATT.NET>]

William and all,



The DOT exemption for certain liquid scintillation fluid and animal

carcasses is found in DOT regulation 49 CFR 173.427 as follows



(d) Except for transportation by aircraft, LSA material and SCO that

conform to the provisions specified in 10 CFR 20.2005 are excepted from

all requirements of this subchapter pertaining to Class 7 (radioactive)

materials when offered for transportation for disposal or recovery. A

material which meets the definition of another hazard class is subject

to the provisions of this subchapter relating to that hazard class.



Regards,

Wes

Wesley R. Van Pelt, PhD, CIH, CHP

Wesley R. Van Pelt Associates, Inc.

Radiation Safety and Environmental Radioactivity

wesvanpelt@att.net





> -----Original Message-----

> From: William V Lipton [mailto:liptonw@dteenergy.com]

> Sent: Thursday, January 23, 2003 10:45 AM

> To: Wes Van Pelt

> Cc: radsafe@list.vanderbilt.edu; Redmond, Randy (RXQ)

> Subject: Re: Surface Contaminated Objects and release limits

> 

> I wasn't aware of this exemption.  Where is it stated in the DOT

> regulations?

> 

> The opinions expressed are strictly mine.

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

> Curies forever.

> 

> Bill Lipton

> liptonw@dteenergy.com

> 

> 

> Wes Van Pelt wrote:

> 

> > Randy and all,

> >

> > ...

> 

> > A similar "conflict" existed some years ago. "Deregulated" materials

> under

> > NRC regulation 10 CFR 20.2005 were still radioactive for shipping

> purposes.

> > As a result of this "conflict", the DOT exempted from its

regulations

> all

> > material meeting the requirements of 10 CFR 20.2005. Perhaps DOT

would

> be

> > willing to do this again for a broader class of unconditionally

released

> and

> > unregulated radioactive material.







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