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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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