In assessing the average specific activity, all radioactive material attributed to the object, i.e., both the distributed activity and the activity of the surface contaminations, needs to be included. As appropriate, additional requirements applicable to LSA material need to also be satisfied in order for the objects to qualify as LSA material. If the SCO contamination limits are exceeded, a Type A or Type B package would be needed, depending on the A 2 fraction in the package. Pre-shipment processing of materials may change the category of material. For example, if contaminated pieces of tubing were collected and compacted, reducing the internal void spaces, a material which would be SCO if uncompacted could be better characterized as LSA after compaction.
Incineration is another, more obvious example of pre-shipment processing.
Some judgement on the part of the licensee and inspectors will be necessary in this area. No Specific guidance. The authorized contents specified on these certificates are based on the LSA definitions from the old rules. The IAEA models justifying the special rules applied to LSA shipments, assume uniform distribution of any LSA material released from the package. A quantitative standard has not been developed, and NRC and DOT are currently considering guidance development.