DoT rule

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

The relevant number is 2nCi/g, not 2 microCi/g.
This is not a BRC issue.
It simply is a threshold below which RAM is not considered Hazardous Material
for the purpose of regulatory control.  Hence, below 2 nCi/g material can
be transported without regard to it radioactive content.

But if the material is from a licensed source it is still licensed material
subject to NRC rules.
And of course, if you are a licensee once you acquire this material within
the scope of your license NRC will probably consider it licensed material,
which raises an interesting question....
If you acquire RAM thru environmental sampling for which you don't have a
license are you in trouble?

Years ago NBS was (and still is) selling envirmental soil standards certified
(among others) as to its Pu-239 content.  No licensed activity was added.
All material came from the 'environment'.  People were having to get a license
to buy the standard until NRC declared this material not to be subject to
NRC rules.  It took several years to get this ruling, but the point is that
the system can be reasonable on occasion.

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life