Re: Package Monitoring

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

49 CFR has requirements for package radiation, thermal &
contamination (173.441, .442, .443).
Contamination and radiation levels should be checked upon arrival of the
package. The radiation levels on the bottom of packages is the most
missed reading on radioactive shipments. I have seen a lead pig designed
for a source read 100 mr/hr on the bottom of the container. The pig
weighted 100 lbs. as long as the pig sat on thr floor the readings were
under 40 mr/hr on the top and sides. The high readings was discovered
when we attached the pig to an over head crane to read the bottom of the
container. The manufacturer sent a larger shipping pig to replace the
improper one. The FAA was informed of the situation and an investigation
was conducted.

Alan R. Marchand
Las Vegas, NV
radarm@accessnv.com

At 02:59 PM 7/23/98 -0500, you wrote:
>Tony,
> 
>Surface contamination monitoring is required for all labeled
radioactive
>material package unless the contents is a gas or special form.
> 
>Type A quantities are excluded from external radiation level
monitoring,
>although I strongly recommend it as good practice.
> 
>All packages are required to be monitored for contamination and
external
>radiation levels if there is indication of damage.
> 
>Roy A. Parker, Ph.D.
>Radiation Physics Consultant to
>Federal Express Corporation
>E-Mail: 70472.711@compuserve.com
>Tel: 504-924-1473
>Fax: 504-924-4269
>-----------------------------10 CFR
20.1906-----------------------------
>             Procedures for receiving and opening packages.
> 
> 
>20.1906 Procedures for receiving and opening packages.
> 
>(a) Each licensee who expects to receive a package containing
quantities
>of radioactive material in excess of a Type A quantity, as defined
in
>71.4 and appendix A to part 71 of this chapter, shall make
arrangements
>to receive --
> 
>(1) The package when the carrier offers it for delivery; or
> 
>(2) Notification of the arrival of the package at the carrier's
terminal
>and to take possession of the package expeditiously.
> 
>(b) Each licensee shall --
> 
>(1) Monitor the external surfaces of a labeled package for
radioactive
>contamination unless the package contains only radioactive material
in
>the form of a gas or in special form as defined in 10 CFR 71.4;
> 
>(2) Monitor the external surfaces of a labeled package for
radiation
>levels unless the package contains quantities of radioactive
material
>that are less than or equal to the Type A quantity, as defined in
71.4
>and appendix A to part 71 of this chapter; and
> 
>(3) Monitor all packages known to contain radioactive material
for
>radioactive contamination and radiation levels if there is evidence
of
>degradation of package integrity, such as packages that are
crushed,
>wet, or damaged.
> 
>(c) The licensee shall perform the monitoring required by paragraph
(b)
>of this section as soon as practical after receipt of the package,
but
>not later than 3 hours after the package is received at the
licensee's
>facility if it is received during the licensee's normal working
hours,
>or not later than 3 hours from the beginning of the next working day
if
>it is received after working hours.
> 
>(d) The licensee shall immediately notify the final delivery
carrier
>and, by telephone and telegram, mailgram, or facsimile, the
>Administrator of the appropriate NRC Regional Office listed in
appendix
>D to part 20 when --
> 
>(1) Removable radioactive surface contamination exceeds the limits
of
>71.87(i) of this chapter; or
> 
>(2) External radiation levels exceed the limits of 71.47 of 
this
>chapter.
> 
>(e) Each licensee shall --
> 
>(1) Establish, maintain, and retain written procedures for
safely
>opening packages in which radioactive material is received; and
> 
>(2) Ensure that the procedures are followed and that due
consideration
>is given to special instructions for the type of package being
opened.
> 
>(f) Licensees transferring special form sources in licensee-owned
or
>licensee-operated vehicles to and from a work site are exempt from
the
>contamination monitoring requirements of paragraph (b) of this
section,
>but are not exempt from the survey requirement in paragraph (b) of
this
>section for measuring radiation levels that is required to ensure
that
>the source is still properly lodged in its shield.
> 
>[56 FR 23401, May 21, 1991, as amended at 57 FR 39357, Aug. 31, 1992;
60
>FR 20185, Apr. 25, 1995]
>-------------( Forwarded computer archived letter follows
)-------------
>    23-Jul-98 14:08 CDT
>Sb: Re: 7 A Package Testing
>From: "Tony LaMastra" <alamastra@enter.net>
>To: Multiple recipients of list
<radsafe@romulus.ehs.uiuc.edu>
> 
>Don:
> 
>I was not aware that the recipient was required to leak test a
package
>under DOT regs.   The NRC requires such testing in 20.1906, but
excludes
>Type A quantities or less.   As far as I know, generally
licensed
>devices should contain less than Type A (possible exception might
be
>cobalt 60 which has an A1 limit of 10.8 Ci - there could be a need
for a
>density or level gauge in this range).
> 
>Tony LaMastra
>alamastra@enter.net
> 
>----------
>> From: Mercado, Don <don.mercado@lmco.com>
>> To: Multiple recipients of list
<radsafe@romulus.ehs.uiuc.edu>
>> Subject: 7 A Package Testing
>> Date: Thursday, July 23, 1998 12:49 PM
>>
>> Good morning,
>>
>> I'm interested in finding out how facilities that have no
radioactive
>> materials testing capabilities handle the 3 hour leak test
requirement
>> for DOT spec packages. A friend of mine working for a company
that has
>> no radioactive materials license will soon be receiving some
generally
>> licensed devices that are shipped in 7 A Type A packages. They
have no
>> measurement devices for package wipe analysis, and I don't know
if
>> they can contract that out.
>>
>> Any advice would be helpful, and I'll pass it along. Thank you
in
>> advance.
>>
>>
>> Donald P. Mercado
>> Radiation Safety Officer
>> Lockheed Martin Missiles & Space
>> O/47-20, B/101
>> 1111 Lockheed Martin Way
>> Sunnyvale, CA 94089
>> Ph. (408) 742-0759
>> Fax (408) 742-0611
>> Email: Don.mercado@lmco.com
> 
>