Transporting Wipes -Reply

[Jim Hardeman <Jim_Hardeman@mail.dnr.state.ga.us>]

Roy --

Thanks for essentially describing our procedure for
transporting samples collected during an incident response.
FEMA and EPA have reviewed these procedures (there are 2
more of the 35 agencies previously mentioned <g>) along
with our "chain of custody") when we last had our mobile
radiation laboratory observed during a REP exercise.

Seems VERY reasonable to me ... and not much of an
administrative burden. Thanks for adding some "sense" to
this discussion.

Jim Hardeman, Manager
Environmental Radiation Program
Environmental Protection Division
Georgia Department of Natural Resources
4244 International Parkway, Suite 114
Atlanta, GA 30354
(404) 362-2675  fax: (404) 362-2653
Jim_Hardeman@mail.dnr.state.ga.us
hardeman@mindspring.com

>>> "Roy A. Parker" <70472.711@CompuServe.COM>
03/31/97 10:29 >>>

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.
 
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.

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.