RE: Shipping samples under DOT HM-230 Final Rule on TrasportationofRadioactive Material

["Bill Lohner" <Bill.Lohner@EPA.STATE.OH.US>]

Thank you.



Let me try another example....



We oversee a site with a Pu-238 clean-up goal of 55 pCi/g.  After clean-up is complete we take confirmatory samples.  The exempt quantity for Pu-238 is 27 pCi/g.  We are somewhat likely to exceed 27 pCi/g in our samples.



Our course of action would then be to screen our samples prior to shipment.  If they exceed 27 pCi/g then we are required to ship as Class 7 radioactive material.



NOTE: under the old rule, 2000 pCi/g, we were exempt from DOT and NRC regulation for transportation of radioactive materials.



>>> "McLamb, John (NIH/NIEHS)" <mclamb1@niehs.nih.gov> 10/08/04 01:33PM >>>

The exception is built into the definition.



Under the new definition (below), the sample must be greater than BOTH the

concentration limit and the activity limit to be considered radioactive for

shipment.  For example a tritium sample would not be considered radioactive

if either the concentration is less than 27 uCi/g or the total activity is

less than 27 mCi.



	From Sec. 173.403  Definitions

	Radioactive material means any material containing radionuclides 

	where both the activity concentration and the total activity in the 

	consignment exceed the values specified in the table in Sec. 173.436

or values derived according to the instructions in Sec. 173.433.



John



John S. McLamb, RRPT

Health Physicist

NIEHS, MD F0-07

P.O. Box 12233

Research Triangle Park, NC  27709

Phone: (919) 541-4235

Fax:  (919) 541-1893







-----Original Message-----

From: Bill Lohner [mailto:Bill.Lohner@EPA.STATE.OH.US] 

Sent: Friday, October 08, 2004 10:27 AM

To: radsafe@list.vanderbilt.edu 

Subject: Shipping samples under DOT HM-230 Final Rule on Trasportation of

Radioactive Material



After review of this rule, the change in definition of radioactive material,

would require Class 7 shipping requirements for samples previously not

regulated by DOT or NRC (2000 pCi/g)  for the purposes of shipment if the

concentration of the sample might exceed the exempt concentrations listed in

Table of Exempt Material (173.436).



Is there any exemptions for small quantities, such as soil samples and air

filters that have a chance of exceeding the exempt quantities?



Any help on this issue would be greatly appreciated.





Bill Lohner

Office of Federal Facilities Oversight

Ohio Environmental Protection Agency

PH: 937.285.6051





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

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 can view the Radsafe archives at

http://www.vanderbilt.edu/radsafe/



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

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 can view the Radsafe archives at

http://www.vanderbilt.edu/radsafe/