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49CFR173.427 LSA Dose Rates



Radsafers,
	Since 49CFR173 seems to be the hot topic today, I'll add another question.

	173.427 Section a.1 has a requirement that the dose rate from LSA
unshielded material be less than 1 rem/hr at 3 meters.  We have
interpretted this to mean the 3 meter dose rate minus shielding from the
container.  As this is different from our normal part 173.441 dose rate
limits, we are contemplating how to measure/calculate this for
documentation purposes.  The packages are sealed and ready for shipment.
Our plan is to measure the package contact dose rate, then back calculate
an unshielded dose.  Intuitively, if the dose rates on the package (B-25
for example) comply with 173.441 limits, then the 3 meter dose rate should
not be a problem.
	 The question is, how are other sites doing this for packaged materials.

Thanks in advance,

Kelly Ausbrooks
ausbrookskl@ornl.gov
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