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Re: LSA vs A2 Requirements
49 CFR 173.427(b)(2) does not, in itself, place a limit on the total
activity
in a LSA or SCO package. It is one of the packaging options. This is a
complex area. You have to read the whole section carefully, along with the
definitions in 173.403. You should also read the guidance in NUREG 1608.
It
also sounds as if you have not met the training requirements of 49 CFR 172,
Subpart H.
If you're asking this question out of curiosity, no problem. If you're
actually trying to ship something, however, all I can say is that it'd
better
be "Masterpiece Theater," not "The Amateur Hour."
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
You wrote:
>Here's one for all you folks knowledgeable about DOT regs. Uniformly =
>contaminated solid material may be classified as LSA II if its specific =
>activity does not exceed 10^-4 x A2 per gram. My question relates to 49 =
>CFR 173.427 (b)(2). Which interpretation is correct:
>1. Does this citation give an unlimited total curie content per package =
>as long as the specific activity requirement is met? OR
>2. Does this citation's reference to a Type A package refer back to the =
>definition of a "Type A package" that includes a curie content limit of =
>A2?
>Obviously, this interpretation has a deciding role on the size of =
>package for LSA II material.
>Thank you.
>Bill Goldsmith
>wagoldsmith@mindspring.com
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