[ RadSafe ] Depleted uranium shipping question

[Walter Cofer]

Carl -

Are you sure you "need" to have the DU item shipped to your residence?  If
you are a nuclear engineering grad student at OSU and the item is related to
your research, you should have the shipment handled by the OSU radiation
safety office, whose personnel are trained and operate under a broad scope
radioactive materials license.

To discourage you from going forward on your own, I'll take a stab at
responding to your request, with the usual caveats and disclaimers.  First
off, in all likelihood, it's incorrect to call your DU "license-exempt,"
because while possession of the item should not require you to apply for and
obtain a specific radioactive materials license, possession of < 15 lb. DU
means you would probably become an Ohio general licensee, under general
license (GL) provisions for source material possessed for R&D, educational,
commercial or operational purposes.  My quick search of the OH Admin. Code
at http://www2.odh.ohio.gov/Rules/rulesfinal.html failed to turn up the GL
requirements for source material, but I'm confident that it's covered in
there somewhere; a call to the OH Dept. of Health's Bureau of Radiation
Protection in Columbus (614/644-2727) should get you to the applicable
rules.   GL provisions vary among states, so the only way to know for sure
what the requirements are is to get the scoop straight from the agency with
jurisdiction over the material.  GL fees can range from zero to hundreds of
dollars/year. 

As for transportation requirements, a lot depends on how the item is
shipped, but it's never that simple, because you must contend with both U.S
and U.K. regs, plus shipper requirements (either IATA/ICOA for air shipments
or IMO for maritime shipments).  The item would likely be classified as
"Radioactive material, excepted package - articles manufactured from
depleted uranium" (Hazard Class 7, ID No. UN2909), provided the package
meets the following:

(1)	General design requirements of 49 CFR 173.410;
(2)	Radiation levels at any point on the external surface of the package
< 0.005 mSv/hour (0.5 mrem/hour);
(3)	Nonfixed (removable) radioactive surface contamination on the
external surface of the package < limits specified in 49 CFR 173.443(a);
(4)	Outside of inner packaging or, if there is no inner packaging, the
outside of the packaging itself bears the marking ''Radioactive'';
(5)	Package contains < 15 grams of U-235; and
(6)	The material is otherwise prepared for shipment as specified in
accordance with 49 CFR 173.422.

The package would have had to meet "strong, tight, package" requirements, be
marked on the exterior with the "UN2909" no., and most significantly, anyone
handling the package during the course of the shipment has to have completed
hazmat training requirements specified in 49 CFR Part 172, Subpart H, which
is no small task.  Access USDOT hazmat regs at
http://www.myregs.com/dotrspa/.

Even if you comply with all of the above requirements, you would still need
to research the UK's RAM transport rules and the IATA/ICOA/IMO requirements.
Since IATA/ICOA/IMO regs are not available online, you'll be hard pressed to
review their requirements (no small task even if you had them, trust me),
and shippers will reject shipments that don't meet their requirements. 

USDOT fines for noncompliant shipments and lack of training are steep (see
49 CFR, Part 107, Subpart D, Appendix A), so you better make sure you get it
right.

A final consideration - possession of a DU item might just get you under the
scrutiny of the Dept. of Homeland Defense; the feds tend to suspect the
worse, so are you prepared to deal with whatever they may think of your
intentions regarding the item?  You need to think long and hard about
possible consequences before proceeding.


Walt Cofer
Radiation Control, Inc.
Tallahassee, FL 



-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Carl Willis
Sent: Monday, July 11, 2005 5:33 AM
To: radsafe at radlab.nl
Subject: [ RadSafe ] Depleted uranium shipping question

Hello RadSafers!

I need some help.  I need to have a small, license-exempt (less than ~ 10 lb
metal) depleted uranium item shipped from a residence in the UK to my
residence in the USA.  Given the political climate these days, I want to
make sure everything is actually done legally and properly.  Can anyone
offer shipping advice, either specific or general, about this situation?  In
particular, can anyone recommend a carrier that will handle the item?

Thanks.

Carl Willis
USDOE Nuclear Engineering Graduate Fellow
The Ohio State University
101 Curl Dr. #1335
Columbus, OH 43210
(505) 412-3277
willlis.219 at osu.edu
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