Re: A shipping query

["Duane Schmidt" <DWS2@NRC.GOV>]

Joel,



In response to your question 1:

This is not my specific area, but there is an underlying general comment that should be made. You should note that the exemptions provided in 10CFR30.15 are exemptions from licensing and from compliance with certain NRC regulations. This does not provide any exemption from other requirements (DOT). Section 30.15(a) [the introduction, if you will] indicates the specifics of what requirements a person is exempted from. NRC does not generally exempt a person from regulations of other agencies (DOT or others).



So, it comes down to the DOT definitions and requirements, for which perhaps someone else will comment.



Duane.



Duane Schmidt, CHP

U.S. Nuclear Regulatory Commission

NMSS/DWM/DCB

dws2@nrc.gov



>>> Joel  Baumbaugh <baumbaug@NOSC.MIL> 4/17/2001 11:41:51 AM >>>

         Hello all,



         <snip>

         My two quick and (perhaps not so) simple questions are:



         1. Do Survey Meters which contain sources which are less than one 

exempt quantity, as a check source (less than 10CFR30.71) need "shipping 

papers" to transport them from one location to another over public roads? 

They "appear" to be exempt from those requirements by 30.15 due to their 

(and the other exempted items listed) "unique" classification.



       

         The reason I ask this is that they "appear" to fall under the same 

exemptions given to Exempt Concentrations (10CFR30.14) and Certain items 

containing byproduct material (10CFR30.15) which do NOT require shipping 

papers because they have been exempted into a "unique" classification 

(along with electron tubes, wrist-watches, compasses, etc.), which IMHO, 

are NOT meant to be covered/governed under 49CFR.



         At this time, I am shipping all survey meters as "Limited 

Quantities of Radioactive Materials" under 49CFR, and I feel that it is 

costing my Command MANY thousands of dollars a year (in training and 

shipping) which, IMHO, could best be spent somewhere else.



         I would appreciate any comments/suggestions (let's keep it clean 

here) and dialog, which would help ME come to an understanding on this 

subject.  You know, I've been in this "business" for over 20 years and its 

the "gray" areas that give me the most headaches (grin)...





         Thanks (and I apologize for multiple postings on other "lists"...),





         Joel Baumbaugh (baumbaug@nosc.mil)









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