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RE: Apparent Illegal Shipment
There are several generic exemptions that have been isssued by DOT for
these type situations. for instance scrap metal can be returned to the
shipper is it alarms a radiation monitor as long as the reading is less
than 50 mr/hr and an exemption form is filled out. The regulatory
authorities in the receiving state should also be notified. I am
operating from memory on this since I havent done it in 6-7 years but it
is a very simple process and DOT granted the exemption since the hazard
is very low and it is not an uncommon occurance.
In my younger days I could have provided you with exemption numbers etc.
but ......
Marty Bourquin
W.R.Grace & Co
marty.bourquin@grace.com
-----Original Message-----
From: liptonw@DTEENERGY.COM [mailto:liptonw@DTEENERGY.COM]
Sent: Friday, February 13, 2004 11:44 AM
To: idias@interchange.ubc.ca
Cc: radsafe@list.Vanderbilt.Edu; norm-tenorm@yahoogroups.com
Subject: Re: Apparent Illegal Shipment
DOT regulations do not distinguish between NORM-TENORM, etc. and NRC
licensed
material. Radioactivity is radioactivity. (What a concept!) Here's the
DOT
definition (49 CFR 173.403: "Radioactive material means ANY material
having a
specific activity greater than 70 Bq per gram (0.002 microcurie per
gram)" In
October, this will change to radionuclide specific values, to achieve
"harmonization" with international regulations; something that bothers a
AAA
card holder such as me.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
John R Johnson wrote:
> Bill et al
>
> This is probably some NORM. Several years ago there was a rail car
with
> recycled scrape pipes, etc going back and forth between Fort Nelson
and the
> recycle yard in Prince George, BC. The recycle yard was rejecting it
because
> it alarmed their monitors but the oil company did not know it was
> radioactive. I was doing a contract with Petro Canada at the time and
found
> out that there is no clear regulatory limits for NORM, or TENORM as
the ANSI
> committee prefers to call it.
>
> _________________
> John R Johnson, Ph.D.
> *****
> President, IDIAS, Inc
> 4535 West 9-Th Ave
> Vancouver B. C.
> V6R 2E2
> (604) 222-9840
> idias@interchange.ubc.ca
> *****
> or most mornings
> Consultant in Radiation Protection
> TRIUMF
> 4004 Wesbrook Mall
> Vancouver B. C.
> V6R 2E2
> (604) 222-1047 Ext. 6610
> Fax: (604) 222-7309
> johnsjr@triumf.ca
>
> -----Original Message-----
> From: owner-radsafe@list.vanderbilt.edu
> [mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of William V
Lipton
> Sent: February 13, 2004 5:20 AM
> To: radsafe@list.vanderbilt.edu
> Subject: Apparent Illegal Shipment
>
> I noticed the attached event in the NRC Daily Event Report. A truck
> arriving at a waste incineration facility alarmed a radiation monitor
> and was found to be reading 0.13 mrem/hr. According to the report,
> "...The driver of the truck was told to return the load back to its
> origin, BFI facilities, in Peabody, MA without any stops...." This
> implies that the site made a radioactive materials shipment without
the
> required DOT controls. Assuming the material shipped would qualify
as
> a "Limited Quantity", they needed the required notice, and the driver
> had to be hazmat employee trained. It does not seem that this was
done,
> although I say, "apparent," because the report may be incomplete.
This
> would be a violation of DOT regulations. If the contamination is
> identified as NRC licensed material, this would also be a violation of
> NRC regulations. It does not seem that anyone involved, including the
> MA regulators, noticed this.
>
> Recognizing that this type of shipment represents a low degree of
> hazard, DOT has issued exemptions, which may allow this shipment to
> procede without meeting all of the normal DOT requirements (DOT-E
11406
> for waste, DOT-E 10656 for scrap metal). These exemptions require
> approval by state authorities. Again, I say "apparent," since one of
> these exemptions may have been used and not noted in the report.
>
> I'd appreciate further information on this.
>
> The opinions expressed are strictly mine.
> It's not about dose, it's about trust.
> Curies forever.
>
> Bill Lipton
> liptonw@dteenergy.com
>
> General Information or Other Event Number: 40511
> Rep Org: MA RADIATION CONTROL PROGRAM
> Licensee:
> Region: 1
> City: HAVERHILL State: MA
> County:
> License #:
> Agreement: Y
> Docket:
> NRC Notified By: MARIO IANNACCONE
> HQ OPS Officer: CHAUNCEY GOULD Notification Date: 02/10/2004
> Notification Time: 11:12 [ET]
> Event Date: 02/10/2004
> Event Time: [EST]
> Last Update Date: 02/10/2004
> Emergency Class: NON EMERGENCY
> 10 CFR Section:
> AGREEMENT STATE
> Person (Organization):
> KENNETH JENISON (R1)
> ROBERTO TORRES (NMSS)
>
> Event Text
>
> LOAD OF WASTE ARRIVING AT A WASTE-TO-ENERGY FACILITY SET OFF RADIATION
> MONITORS
>
> A load of waste or recycle materials that had been transported to
> Covanta Haverhill, Inc (a waste-to-energy facility) in Haverhill, MA
had
> a radiation measurement of 0.13 mrem/hr when it entered the facility.
> The driver of the truck was told to return the load back to its
origin,
> BFI facilities, in Peabody, MA without any stops. Once at the origin
of
> the shipment, the load is to be isolated until mitigation by a
> consultant. A report detailing material identification and disposition
> shall be submitted to the MA Radiation control Program.
>
>
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