H3 Shipment

[RON LAVERA <lavera.r@nypa.gov>]

Tom,
      With the details you have provided I can suggest that the
situation is
as follows. 9 curies of H3 in the situation you describe
qualifies as a
limited Quantity 49 CFR 173.421( 2.0X10-2 A2).
As such the only packaging requirements would be a
package that meets
the general design criteria specified in 173.410.
      Assuming all the dose rate and contamination criteria
are met as well
as any applicable requirements from 173.421, I would say
that you do
NOT have a violation. HOWEVER, if you had , the problem is
who to tell.
In a situation such as this, our first approach would be to
notify the
shipper and then D.O.T ( they don't provide any specific
contact point, but
it is THEIR regulation being violated.) If the avenue is
available to you a
courtesy notification top the NRC or state licensing body
would be
appropriate. ( You might want to check any state regs which
could apply)
I hope this helps..... I have been there before and it's pretty
frustrating....If
you have any further questions I'm at   j.lepere@nypa.gov
Good Luck,
 John LePere
 Waste Management General Supervisor
 New York Power Authority
 Indian Point #3 NPP (914) 736 8470