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

["Nardi, A. Joseph" <nardiaj@westinghouse.com>]

In my previous message I calculated that at 54 pCi/g it would take about a

half a ton of soil to meet the quantity exemption amount for Pu-238.  I made

a calculation error.  It would only take about 5 kgs of soil.



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: Nardi, A. Joseph 

Sent: Friday, October 08, 2004 4:10 PM

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

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

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



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