ML19270F549
| ML19270F549 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/1979 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Doles A EBERLINE INSTRUMENT CORP. |
| Shared Package | |
| ML19270F550 | List: |
| References | |
| RULE-PRM-70-6, TASK-OS, TASK-TP-713-3 NUDOCS 7902150426 | |
| Download: ML19270F549 (2) | |
Text
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NUCLEAR RsCULATORY COMMisslGN 3
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J;Jt 1 i fm PRM-70-6 Mr. A. E. Doles, Vice President Eberline Instrument Corporation P.O. Box 2108 Santa Fe, New Mexico 87501
Dear Mr. Doles:
This is in response to your letter dated January 9,1979, regarding' air shipment of plutonium.
It is important to distinguish a plutonium shipment frcm a shipment of some material that may be contaminated with plutonium. We agree with you and the Department of Energy (DOE) that environmental samples containing minuscule amounts of plutonium, such as soil samples con-taminated by plutonium fall-out from atmospheric weapons testing, are not to be considered as plutonium shipments, and therefore, such environmental samples are not subject to the restrictions imposed by the Public Law 94-79. We have stated this position in a letter to Congressman Manuel Lujan, Jr., dated February 3,1976, responding to a letter sent to the Congressman from Mr. William S. Johnson, Sr.,
Chairman of your company.
The level of plutonium contamination in the environmental samples below which these samples are not to be considered as a plutonium shipment can be determined based on current regulations. The NRC's regulation,10 CFR 71.5, states that licensees who transport licensed material shall comply with the applicable requirements of the reguiu..as of the Depart-ment of Transportation (DOT) which defines rad cactive materials for the purpose of transportation. The DOT's regulation, 49 CFR 173.389(e),
states that any material or combination of materials in which the estimated specific activity is not greater than 0.002 microcurie per gram of material and in which tne radioactivity is essentially uniformly distributed should not be considered as racloactive material. Therefore, any shipments con-taining materiais, including environmental samples, that satisfy the above criteria with respect to plutonium are not considerad to be plutonium shipments.
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A, E. Doles,%1 2 4 M In the case of the petition submitted to NRC by your company, the subject deals with air transport of small plutonium sources. Under the current provisions, plutonium shipments (except plutonium con-tained in a medical device desi ned for individual human application) 5 may be transported by air only in packages of a design specifically certified by the NRC for that purpose, even though the plutonium ship-ment contains a very small plutonium source.
Please contact me if you have further questions.
In the meantime, as I stated in my previous letter dated December 29, 1978, we will promptly seek the Commission's decision on this subject.
Sincerely, llc;b4Yb' f0Lwe9vu<
Robert B. Minogue, Difector Office of Standards Development
.