DOT Question

["Oldewage, Hans D" <HDOLDEW@SANDIA.GOV>]

I am confused on the applicability of the DOT radioactive material shipping

regulations for individuals or businesses that are not subject to NRC

licensing. If an individual or business were to transport radioactive

material or waste that is exempt from licensing, but is greater than 2

nanocurie/gram specific activity (e.g. glazed ceramic tableware that does

not exceed 20% by weight source material) is that individual or business

still subject to 49 CFR 171-180?  What if a company or individual were to

dispose of this material as solid waste in a municipal landfill, since it is

exempt and does not require management as radioactive waste?  Would the

shipment require labeling, manifesting, placarding as appropriate under 49

CFR?



Would the transportation regulations be any different if it were 1) my own

personal fiestaware that I want to take to the dump? or 2) fiestaware

purchased by and for a DOE facility for public outreach demonstrations that

is no longer useable?



Opinions are alsways welcome, but facts and personal experiences are best...



Thanks in advance,

Hans

=======================

Hans Oldewage

Sandia National Laboratories

(505)845-7728

hdoldew@sandia.gov





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