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RE: Shipping samples under DOT HM-230 Final Rule on Trasportationof Radioactive Material
Glad to see people are finally reading this thing. Think about a site that
can send uranium contaminated waste to a landfill (35 pCi/gram landfill
criteria), if it goes over public roads and is 27 pCi/gram it has to be
shipped as radioactive material.
Randy Redmond
Oak Ridge, TN
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu
To: 'Bill Lohner'; radsafe@list.vanderbilt.edu; mclamb1@niehs.nih.gov
Sent: 10/8/2004 4:10 PM
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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