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



even though we would like to, risk estimates and assessments are not categorically transferrable from one type of scenario to another. even within the same scenario type, the assessment is changed by the scenario differences. transportation and site use are two totally different scenarios though involving the same material. one basic caveat is the duration of exposure possibilities. also keep in mind that the transportation risk management objective is different from the risk management objective at the site. the transport objective is simply to cut expense and facilitate a transient risk of exposure though the release might be sudden. should the material release, it would be considered a high risk event for the immediate deposition area. such a release is not expected at the released site. 



removing soil from a risk based released site could be a violation unless done properly because the material was considered of low risk based on exposure scenarios at the closed site based on use scenarios and other enviro and isotope factors.



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

From: Nardi, A. Joseph [mailto:nardiaj@westinghouse.com]

Sent: Friday, October 08, 2004 1:10 PM

To: 'Bill Lohner'; radsafe@list.vanderbilt.edu; mclamb1@niehs.nih.gov

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

Trasportation of Radioactive Material





What you are saying is a very real problem.  But not especially for samples.

At say 54 pCi/g final soil concentration you would be more than the exempt

concentration by a factor of 2, less than your release criteria, but you

would most likely still fit under the quantity exemption for Pu-238

contaminated samples which I calculate would take about a half a ton of

soil.  The problem will exist because after you release the site at less

than 55 pCi/g the next owner would be in violation of DOT rules if they cart

a dump truck load of soil off the site.  This problem is not unique to

Pu-238 but also exists for even natural and enriched uranium.  I have not

checked all radionuclides but for example, for Co-60 the DOT exempt

concentration is 270 pCi/g which is generally higher than the site release

criteria that I have seen.



What is needed is for someone to take a hard look at the modeling that went

into establishing the exempt concentrations provided in the IAEA regulations

and to explain why that modeling says that these concentrations need to be

regulated for purposes of transportation when they are acceptable to be left

on a site even under conservative modeling assumptions of residential

occupation.



 A. Joseph Nardi

Westinghouse Electric Company

P.O. Box 355

Pittsburgh, PA 15230

Phone - 412-374-4652

FAX - 412-374-3357

email - nardiaj@westinghouse.com



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

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

Sent: Friday, October 08, 2004 1:38 PM

To: radsafe@list.vanderbilt.edu; mclamb1@niehs.nih.gov

Subject: RE: Shipping samples under DOT HM-230 Final Rule on Trasportationof

Radioactive Material





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





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