Re: H3 Shipment

[tom baccus <baccus@physics.isu.edu>]

At 10:55 AM 7/6/1998 -0500, you wrote:
>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 
>
John,

I appreciate your response.  The problem I have with the values listed in
table 7, is that they are for instruments and articles.  The definition for
instrument and articles clearly states the the radioactivity is a component
part of the instrument or article.  I do not beleive that a vacuum pump
contaminated with 9 Ci of H3 meets this definition.