Re: DOT Question

[BLHamrick@AOL.COM]

In a message dated 4/1/2003 12:06:26 PM Pacific Standard Time, HDOLDEW@SANDIA.GOV writes:


> 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?



A strict reading of the regulations would seem to indicate the answer to your questions are yes, yes and yes.  The fact that a person may be exempt from the licensing requirements in 10 CFR with respect to the possesion, use, transfer, etc. of certain radioactive items does not imply an exemption from DOT requirements in 49 CFR.  This is an area NRC and DOT may need to visit in concert.


Barbara