No Subject

[Keith Welch <welch@CEBAF.GOV>]

Regarding transportation of radioactive material, technically you could :
(b)..... 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."
        Again, remembering that you can do whatever you want with it as far
as the DOT is concerned.  As was mentioned, NRC might have a "cow" that you
are doing this - but their beef (pun?) could not be that you were
transporting it incorrectly.  They would have to come at it from another
angle - like improper disposal of RAM (assuming you were shipping it for
disposal). If the material is "waste" a dozen or two regulatory agencies are
involved.

I have a question about the transport issue.  A few things were mentioned
such as inability to determine in the field how much radioactivity is there,
what the nuclides are, etc.  i.e.   "Are we to --always-- assume that our
wipes are hot, and package them all by DOT? "  Then someone mentioned doing
just that.  

Questions:  are we talking about transportation within the confines of a
"site",  such as a power plant, laboratory or campus.  And, who is
transporting the swipes?  The person that took them?   How loosely can we
interpret that this material is being "offered for shipment" for purposes of
commerce?  I know some sites have been cornered into considering any
movement of RAM on the site as a shipment - mostly because the stuff travels
a public roadway.  But I would argue that a swipe is a sample that is
"potentially" radioactive, that the amount of RAM on the swipe is not likely
to be significant, and that in most cases it never leaves the possession of
the person who took it.  I agree that it is patently absurd to think about
handling swipe transport as a RAM shipement.  If we had to do this, we might
as well close the doors right now.  I did not catch the first postings on
this topic so I might have missed something.  Has anybody done the math on
this - how many dpm would a typical swipe have to have on it to meet the DOT
definition of RAM.  It would seem to me to be much more than the "typical"
swipe would have.
Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov
Ph: (757)269-7212
FAX:(757)269-5048