Empty RAM Packages

["Roy A. Parker" <70472.711@CompuServe.COM>]

Les,
 
An  empty   packaging  is   defined  as  a  packaging  which
previously contained radioactive material, and:
1. is in a well-maintained condition and securely closed;
2. the outer  surface of  any  uranium  or  thorium  in  the
   package for  shielding is  cover with  an inactive sheath
   made of metal or some other substantial material;
3. the level  of internal  non-fixed contamination  does not
   exceed  one   thousand  times  the  permissible  external
   non-fixed levels for an excepted package which are:
       0.4 Bq/cm^2  for beta,  gamma and  low  toxicity
           alpha; and
       0.04 Bq/cm^2 for all other alpha
4. any   radioactive    labels   (White-I,   Yellow-II   and
   Yellow-III) which may have been display are obscured.
For the  above cases  your cask  would undoubtedly  meet the
requirement for  Radioactive Material,  Excepted  Package  -
Empty Packaging,  n.o.s., UN2910,  which means  that  it  is
excepted   from    any   other    specification    packaging
requirements,   marking,   labeling   and   shipping   paper
requirements.
 
If the  container is  absolute  clean  and  any  radioactive
material does  not exceed  70 Bq/gm then it is not regulated
for transportation;  but this becomes difficult to apply for
surface contamination.  Therefore, using the IAEA definition
for  contamination   from  Safety  Series  6  if  the  total
contamination does not exceed:
       0.4 Bq/cm^2  for beta,  gamma and  low  toxicity
           alpha; and
       0.04 Bq/cm^2 for all other alpha
then it  is not  considered "contaminated" and will not be a
surface contaminated object.  In these cases it would not be
regulated for transportation.
 
In your  example it  may be desirable to obliterate previous
category labels,  apply an  EMPTY label,  and consider it an
excepted package  which will  except you from shipping paper
requirements; because  the EMPTY label will probably relieve
you from  having to obliterate the permanent proper shipping
name markings  on the  cask, which  could become  difficult.
(The EMPTY  label has  the effect  of  negating  the  proper
shipping name  and other  hazardous material markings on the
package.)
 
Roy A. Parker, Ph.D.
Radiation Physics Consultant
to Federal Express Corporation
E-Mail: 70472.711@compuserve.com
504-924-1473
------------( Forwarded computer archived letter follows )------------
DoT has a specific hazardous material
category for shipping 'empty' shipping
containers.
If the container is absolutely clean does
this regulation apply?  That is, is it
hazardous material even if it is not
radioactive?  I can make arguements both ways,
and have specific advice to the negative.
If you had a virgin, 20 ton Type B cask tied
to a truck bed would you would you omit the
empty cask identification and shipping papers?
 
If the answer to the above is negative, how
contaminated would it have to be to necessitate
labeling as an empty container?
 
A little risk adds spice to life.
slaback@MICF.NIST.gov