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RE: Shipping samples under DOT HM-230 Final Rule on TrasportationofRadioactive Material
Thanks to everyone for the replies to this question. It is nice to be able to bounce ideas off of everyone to ensure that we are, at least, consistent..
One last question to bounce:
As I read the reg, no special labeling is required so long as the samples are exempt?
- Bill
>>> "McLamb, John (NIH/NIEHS)" <mclamb1@niehs.nih.gov> 10/08/04 02:07PM >>>
As long as the total activity of Pu-238 in the consignment is less than ..27
uCi the shipment is not classified as radioactive. This means that if you
have samples that have a concentration of 55 pCi/g, you could ship 4.9 Kg of
soil per shipment and not classify it as radioactive.
I hope this helps.
John
-----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; McLamb, John (NIH/NIEHS)
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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