Re: Low level contamination in RAM shipment

[LIPTONW@detroitedison.com]

It's obviously not a violation to receive a package with excessive removable 
contamination, since the receiver has no means for determining this before 
receipt. (It would be a potential violation, if not a poor practice, to
refuse 
such receipt and put the package back in transit, knowing that it is not 
suitable.) The violation is in shipping it!  You are correct, however, in 
stating that it would be a violation for the reciever not to report it, in 
accordance with 10 CFR 20.1906(d). 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com 
 
LIPTONW@detroitedison.com wrote: 
>  
> The removable contamination limit for a package in transit is 2200 dpm/100 
cm2 
> for beta-gamma radionuclides.  Thus, 300 dpm/100 cm2 is not a violation, 
> although I would notify the shipper.  There are no limits on internal 
>  
 
Bill, 
 
Just a fine "legal" point. 
 
You imply that receiving an outer package contamination greater than 
2200 dpm/100 cm2 is a VIOLATION. It is not. It can become a violation if 
you do not do the required immediate notifications. 
 
(I, also, would notify the shipper.) 
 
Best Regards, 
Wes 
--  
Wesley R. Van Pelt, Ph.D., CIH, CHP                KF2LG 
President, Van Pelt Associates, Inc.      
Consulting in radiological health and safety. 
mailto:VanPeltW@IDT.net         
http://shell.idt.net/~vanpeltw/index.html