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Re: 49 CFR 61
You seem to have forgotten that isotopes of flourine, bromine
and all the noble gases have normal boiling points below 100C.
Note that Table 1 of App. E of 40CFR61 contains entries for solid
and liquid forms of tritium, F18, Cl36, etc., all of which have
boiling points below 100C. If the EPA interpreted their reg. to
mean that elements with b.p. below 100C must be considered gases, always,
then these entries would be meaningless. It would appear that one must
consider the boilng point of the specific chemicals containing radio-
active isotopes.