RE: LSA vs A2 Requirements

[Glen.Vickers@ucm.com]

I think I must tend to agree with Mr. Lipton in this area.  It sounds like
Mr. Lipton comes from the power plant world which is heavily scrutinized and
very unforgiving.  I think he is raising a yellow flag appropriately, not
discouraging a questioning attitude.  

You are starting to tread in a relatively complicated area with respect to
packaging criteria and limitations.  Getting involved in DOT 7A, NRC Type B,
1 R/hr at 3 meters from unshielded material, etc., will cause an experienced
shipper to slow down and think twice before acting.  Things in this area
should actually clear up a little once the cask exceptions die 4/1/99, but
there is a greater risk of error in this area as compared to performing the
actual characterization of the material.

Ensuring you know all of the markings and labels required for a NRC Type B
for example, takes a bit of reading.

This is an area where you must do some benchmarking to ensure your
interpretation of the rules is correct.  You must benchmark several credible
sources, never make a decision based on a single opinion.  If, for instance,
you are using a Chem-Nuke cask from Barnwell, get their opinion.  They have
some people which seem to have a good handle on the evolution of cask regs
and exemptions.


Glen Vickers
Nuclear Power HP and waste shipper
glen.vickers@ucm.com

	-----Original Message-----
	From:	LIPTONW@dteenergy.com [SMTP:LIPTONW@dteenergy.com]
	Sent:	Monday, March 29, 1999 6:35 AM
	To:	Multiple recipients of list
	Subject:	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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