Transportation of Wipes for Removable Contamination

["Alan R. Marchand" <radarm@accessnv.com>]

At 04:29 PM 4/5/97 -0000, you wrote:
>
>---------------- Begin Forwarded Message ----------------
>Date:        03/28  12:45 AM
>Received:    03/28  9:48 AM
>From:        Don_Jordan, Don_Jordan@fpm.uchicago.edu
>Reply-To:    Radsafe, radsafe@romulus.ehs.uiuc.edu
>To:          Multiple recipients of list, radsafe@romulus.ehs.uiuc.edu
>
>The ref. for the 70 Bq/gram (0.002 uCi/g) definition of radioactive 
>material
>is 49CFR173.403, Definitions.  If this duplicates other responses, my 
>apologies.
>
>Clearly one can use an inexpensive portable survey instrument to look for
>most of the nuclides
>mentioned, with a lower limit of detection adequate to permit transport as
>non-radioactive material.
>(If you can measure the wipe with the survey instrument, why transport it
>back for analysis?)  The problem,
>of course is tritium.  
>
>One solution would be to take along vials with scint. fluid already in it.
>This additional weight would allow you to transport much higher activities
>than just the wipe alone as non-radioactive material, while maintaining a
>reasonable claim to having the radioactive material "essentially uniformly
>distributed".  I suspect that DOT established the 70 Bq/g lowerr limit
>specifically to avoid
>regulating manifestly trivial quantities of hazmat, and would interpret 
>this
>rule rather generously for 
>such obvious laboratory samples - but of couse, I cannot speak for DoT; 
>on a
>slow day someone might decide
>that the fate of Western civilization depends on stopping such abuses.  
>Don Jordan	
>The University of Chicago	
>Office of Radiation Safety
>Zoology Building Room 11
>1101 East 57th Street
>Chicago,  Illinois  60615
>Tel.	773-702-6299
>Fax	773-702-4008
>email Don_Jordan@fpm.uchicago.edu
>
>
>
>
>----------------- End Forwarded Message -----------------
>>
173.403 Radioactive Material means any material having a specific activity greater than 70 Bq per gram (.002 uCi.)= 4440 dpm.

You can try to create a medium sufficiently large but Table 2 in 172.101, App.A  will create a reportable quantity that will make the package an RQ-Radioactive. I-129 has a reportable quantity of .001 TBq (.000037 Ci.).
Section 173.441  Radiation level limitations will be another consideration. look at Natural Thorium. it has an unlimited A2 value because you cannot put enough of the item in a trailer. But the radiation readings will force you to use section 173.427 for a LSA-I shipment.

A2 value for T is 1,080 Ci. Excepted Package-Limited Quantity amount is 1.08 Ci. Table 7 gives you package limits for Tritium. Meet these limits and all you need is (INNER PACKAGES MARKED RADIOACTIVE and meeting section 173.410.

If you have a mixture of unknown radionuclides, you can break the down to beta and gamma emitters or alpha emitters. 173.433 Table 10 gives you assigned A2 and A1 values. Most of your smear wipes with high quantities will only require an exception statement in the package and a few other requirements (INNER PACKAGES MARKED RADIOACTIVE and meeting section 173.410.

In the field all you can use is actual readings from your instruments or estimate what you expect to collect on the smears to determine if you even meet DOT requirements. By the way, do not forget the Contamination control limits in 173.443 Table 11.

As you can see, 49 CFR reads in stereo and must read all the sections to come out on top.

Alan R, Marchand
Las Vegas, Nv
<radarm@accessnv.com>