Transporting Wipes

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

Again, I  repeat that  I am not trying to defend, justify, nor criticize
the transportation  regulations, but  only trying to present an accurate
and impartial interpretation.
 
> If I understand it correctly, this wording leads me to a couple of
> interesting assumptions:
 
> (a)  if I find a nuclide with an activity less than the microcurie/g
> limit in its pure form, it's not condsidered "radioactive material"
> and I may possess any quantity I choose and do with it whatever I
> choose;
 
> (b)  if I can arrange to uniformly distribute a radioisotope sample in
> a mass of another medium sufficiently large that the whole lot falls
> below the SA limit, it's not condsidered "radioactive material" and I
> can do whatever I want with it.
 
     The assumptions  would be  incorrect.    The  current  0.002  uCi/g
     definition  applies  only  to  the  transportation  of  radioactive
     material.   If the radioactive material is no more then 0.002 uCi/g
     then it may be transported without regard to the hazardous material
     transportation regulations  49 CFR 171-179.   The receipt,  use and
     possession are  entirely different  and separate  issues related to
     agreement state and NRC regulations.
 
> Let's see -- if we pour this 1 Ci sample of I-129 in a carboy, add a
> bottle or two of Scintiverse to dissolve, then add enough water to
> form a good firm gelatinous mass that is of sufficient size, can we
> toss it in the regular waste?
 
     Tossing in  the regular waste has absolutely nothing to do directly
     with its  transportation as  radioactive material.  (It should also
     be pointed  out that  although material is not radioactive material
     for the  purpose of  transportation, it  may be  subject  to  other
     sections of  the  hazardous  material  transportation  regulations,
     because  of   other  substances,   such  as   toluene   in   liquid
     scintillation cocktails.)
 
> On a more serious note:  according to section 3 of your posting, if I
> do a periodic audit of a lab that uses several nuclides in various
> quantities and perform smear wipes, I have to label the wipes packet,
> package it for transport as if it were destined for a third-party
> shipper and tag the vehicle I use to bring them back to the office?
> The idea is patently absurd.
 
> If I find a hot spot during the meter survey, I can be reasonably sure
> that I will have some RAM on one or more of my wipes, but I probably
> won't be able to determine which nuclide I've got, and I certainly
> won't be able to determine the mass of the dust and crud on the wipe
> and calculate the SA from the meter reading.  What if I have a wipe
> that picked up a 0.1 uCi droplet of a tritiated compound?  I'll never
> find it with a meter, so I have no information with which to determine
> whether I've got a hot wipe or just a piece of dusty filter paper.
> Same goes for wipes that are only slightly contaminated with other
> nuclides.  A few hundred DPM/100 sq.cm of most nuclides won't show up
> on a meter survey, but the LSC will certainly find it.
 
     It is  easier in  these cases  to assume  that you have radioactive
     material for  the purpose  of transportation and set up a screening
     procedure to  determine if  the wipe(s) exceed the limited quantity
     of material  limit, usually 0.001 A2, so that it can be transported
     as Radioactive  Material, excepted  package -  limited quantity  of
     material, UN2910.
 
> Are we to --always-- assume that our wipes are hot, and package them
> all by DOT?  The amount on a single wipe is unlikely to be a hazard to
> anyone unless they eat the wipe, but the time and effort on packaging
> and labeling the wipes for the trip from their lab to ours would be a
> real pain.  Imagine expending the effort to meet DOT on this,
> re-opening the box 5 minutes later to load the samples in the LSC,
> then finding that all 100 or so of the wipes you did that day counted
> at or below background.  Could make a person crazy.
 
     One has  to make  a  decision  whether  to  follow  the  applicable
     regulations until  changed or  to run the risk (however slight that
     may be)  of possible enforcement action.  It would not be difficult
     to set  up a  screening technique  to be  certain that  one is  not
     exceeding the  limited quantity  of material activity in a package.
     The next  requirement  is  to  mark  or  label  the  inner  package
     "Radioactive,"  a   marker  pen  or  laboratory  type  "Radioactive
     Material" would  suffice.   Have have  reusable box  that meets the
     applicable general  packaging requirements.   Have  inside that box
     the required 49 CFR 173.422 excepted package notice.  Make sure the
     maximum surface  level on  the outside  of the  box doesn't  exceed
     0.5 mrem per  hour.   This is  a  matter  of  minutes,  except  for
     developing the  screening technique,  which can  be done  once  and
     documented for future use.
 
> On a more serious note:  according to section 3 of your posting, if I
> do a periodic audit of a lab that uses several nuclides in various
> quantities and perform smear wipes, I have to label the wipes packet,
> package it for transport as if it were destined for a third-party
> shipper and tag the vehicle I use to bring them back to the office?
> The idea is patently absurd.
 
     If  the  wipes  can  be  prepared  for  transport  as  "Radioactive
     Material, Excepted Package - Limited Quantity of Material, UN2910,"
     then  it   is  excepted   most  packaging  specifications;  marking
     requirements on the outer package; labeling with White I, Yellow II
     or Yellow  III labels;  and the  vehicle  is  not  required  to  be
     placarded since  it  is  not  transporting  a  Yellow  III  labeled
     package.
 
If it  can be  established that  the total activity in the package is no
more than 10% of the applicable limited quantity of radioactive material
value then  the package can be prepared for mailing without the excepted
package notice.
 
I sincerely  hope that  any discussions  on  this  response  are  solely
limited  to   rational  comments   pertaining  to   the   transportation
regulations.
 
 
Roy A. Parker, Ph.D.
E-Mail: 70472.711@compuserve.com
Tel: 504-924-1473
Fax: 504-924-4269
-------------( Forwarded computer archived letter follows )-------------
    31-Mar-97 07:25 CST
Sb: Re: Transportation of Wipes for Removable Contamination
Fm: Eric Denison > INTERNET:denison.8@postbox.acs.ohio-state.edu
 
 
In article  "Roy A. Parker" <70472.711@CompuServe.COM> writes:
 
>   The  above   definition  of   radioactive  material   references  the
>   definition for specific activity:
>
>     173.403(aa)  Specific  activity  of  a  radionuclide,  means  the
>     activity of  the radionuclide per unit mass of that nuclide.  The
>     specific activity  of a  material in  which the  radionuclide  is
>     essentially uniformly  distributed is  the activity per unit mass
>     of the material.
 
If I understand it correctly, this wording leads me to a couple of
interesting assumptions:
 
(a)  if I find a nuclide with an activity less than the microcurie/g limit in
its pure form, it's not condsidered "radioactive material" and I may possess
any quantity I choose and do with it whatever I choose;
 
(b)  if I can arrange to uniformly distribute a radioisotope sample in a mass
of another medium sufficiently large that the whole lot falls below the SA
limit, it's not condsidered "radioactive material" and I can do whatever I
want with it.
 
Now I'm not sure about (a), but I know good and well that the NRC would have a
cow or several if we tried to pull off (b).  Let's see -- if we pour this 1 C
sample of I-129 in a carboy, add a bottle or two of Scintiverse to dissolve,
then add enough water to form a good firm gelatinous mass that is of
sufficient size, can we toss it in the regular waste?  Don't think so.
 
On a more serious note:  according to section 3 of your posting, if I do a
periodic audit of a lab that uses several nuclides in various quantities and
perform smear wipes, I have to label the wipes packet, package it for
transport as if it were destined for a third-party shipper and tag the vehicle
I use to bring them back to the office?  The idea is patently absurd.
 
If I find a hot spot during the meter survey, I can be reasonably sure that I
will have some RAM on one or more of my wipes, but I probably won't be able to
determine which nuclide I've got, and I certainly won't be able to determine
the mass of the dust and crud on the wipe and calculate the SA from the meter
reading.  What if I have a wipe that picked up a 0.1 uCi droplet of a
tritiated compound?  I'll never find it with a meter, so I have no information
with which to determine whether I've got a hot wipe or just a piece of dusty
filter paper.  Same goes for wipes that are only slightly contaminated with
other nuclides.  A few hundred DPM/100 sq.cm of most nuclides won't show up on
a meter survey, but the LSC will certainly find it.
 
Are we to --always-- assume that our wipes are hot, and package them all by
DOT?  The amount on a single wipe is unlikely to be a hazard to anyone unless
they eat the wipe, but the time and effort on packaging and labeling the
wipes for the trip from their lab to ours would be a real pain.  Imagine
expending the effort to meet DOT on this, re-opening the box 5 minutes later
to load the samples in the LSC, then finding that all 100 or so of the wipes
you did that day counted at or below background.  Could make a person crazy.
 
Eric Denison