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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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