Re: Shipping Violation

[Steve Deitch <StephenD@compuserve.com>]

Tom: 

We discussed the original question around the office.  NSSI's opinion is:

With respect to your question concerning the shipment of a vacuum pump
containing H-3, it would appear that you are asking the wrong people for
clarification. The shipper of a hazardous material is the person who makes
the determination, right or wrong, as to the proper shipping name for the
material. His determination, hopefully, is based on correct information
available to him at the time of shipment. The burden of improper shipment
rests on the shipper as well and exposes him to significant DOT fines. 

As noted by others, more information is needed in order to determine the
proper shipping name and the packaging required. It is not unusual that
several proper shipping names may fit a single radioactive material
shipment. Which one a shipper uses depends not only on the material to be
shipped but what transport mode is to be used and the transport containers
available. 

I could picture an oil type vacuum pump which has the H-3 present as
tritiated oil, or one with H-3 present as tritiated water, or a vac-ion or
other metal absorber type pump where the Tritium is taken up on Titanium
plates. Dependent on which pump is shipped, the packaging and allowable
Tritium content is markedly different. The values vary widely:

Limited quantity      Tritiated water                          1000 Ci
                                  Other liquids                            
      1 Ci      
                                  Gases absirbed on solid carrier     21.6
Ci

Instruments and Articles                                          Not
applicable    

Low specific activity Tritiated water                              20
Ci/liter

Surface contaminated objects                                         20
microCi/cm2    

With respect to reporting a shipping violation, I interpret the regulations
to require such reporting if the receiving wipes or receiving surveys
indicate potential leakage. In other words when a person ships in a manner
in which someone could be injured, the regulations require that
notification be made. With respect to notifying NRC concerning what the
receiver considers to be possibly inappropriate packaging keep in mind that
both the EPA and the NRC have fined licensees who made the mistake of
voluntarily notifying the agencies of deficiencies within the licensees
program.

With respect to notification of the NRC you can bet that your Radsafe
inquiry has already set into motion some regulatory group looking for an
opportunity to enrich it's coffers. I would be surprised if you have not
received a call from one of the agencies wanting all of the particulars
concerning this shipment so they can properly investigate.

For further discussion:

Call Steve Deitch or Bob Gallagher at NSSI

Steve Deitch
NSSI
713 641 0391
stephend@compuserve.com

In this case the opinions expressed ARE the opinions of my employer!