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Re: LSA-1 rule
You are correct. My comment only applied
to the activated materials provision.
What was interesting was my initial contact
with DoT agreed that a liquid activated material
was ok, but later withdrew that interpretation.
My simplistic reading of the rule was based on
the fact that if they intended only solid
activated material' they would have said so. It
seems reasonable to me that one could have
tritiated water above the exempt quantity limit
but below the LSA-1 criteria, e.g., 1 Ci/L, that
could reasonably be shipped as LSA-1. This rule
seemed to acknowledge that despite all the words
about solids in the other portion of the
definition. Not so.
A little risk adds spice to life.
slaback@MICF.NIST.gov