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Re: DOT Question
DOT/RSPA transport regulations for Class 7 (radioactive) material do not
distinguish between licensed and unlicensed radioactive material. These
regulations are, however, limited to: "The offering of hazardous materials for
transportation and transportation of hazardous materials in interstate,
intrastate, and foreign commerce by rail car, aircraft, motor vehicle, or
vessel." (49 CFR 171.1(a)(1)) Thus, if you were transporting personal material,
eg., a smoke detector from the hardware store to your home, or fiestaware from
you home to the dump, DOT/RSPA regulations would not apply. Theoretically, you
could also transport hazardous material by bicycle without having to comply with
DOT/RSPA regulations. In many cases where DOT regulations apply, it may be
possible to ship the material as an excepted quantity, which avoids a lot of the
requirements.
The other issue is that material which is exempt from a license under 10 CFR 30
or 10 CFR 40 may still be subject to the disposal requirements of 10 CFR 20.
This gets complicated.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
"Oldewage, Hans D" wrote:
> 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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