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Re: Shipping Regulations Effective Today
This is not correct. The only reason Part 71 exists is for NRC to review
Type B packages under the memorandum of understanding with the DOT.
Note 10 CFR Part 71 references 49 CFR for NRC licenses, therefore the
voluntary compliance is valid.
Roy A. Parker, Ph.D.
roy@royparker.org
Tel: 225-924-1473
Fax: 225-924-4269
----- Original Message -----
From: "Nardi, A. Joseph" <nardiaj@WESTINGHOUSE.COM>
To: "RADSAFE" <radsafe@list.Vanderbilt.Edu>; "'Roy A. Parker'"
<royaparker@COMPUSERVE.COM>
Sent: Thursday, February 26, 2004 11:31 AM
Subject: RE: Shipping Regulations Effective Today
>
> Be careful about using the DOT provision for early voluntary compliance
> starting 2/25/04. The NRC final rule does not include a provision for
such
> early voluntary compliance. For example if you used the new definition of
> "fissile exempt material" you would be in compliance with DOT but not NRC
> until the full effective date of Oct 1, 2004.
>
> Joe Nardi
>
>
> > ----------
> > From: Roy A. Parker[SMTP:royaparker@COMPUSERVE.COM]
> > Reply To: Roy A. Parker
> > Sent: Wednesday, February 25, 2004 9:35 AM
> > To: RADSAFE
> > Subject: Shipping Regulations Effective Today
> >
> > Effective today, Wednesday, February 25, 2004:
> >
> > 1. You are no longer required to include the "excepted package notice"
in,
> > on or with the package, when shipping an excepted package.
> > 2. You may use the "exempt concentration" and exempt consignment" values
> > to
> > define radioactive material for transportation purposes in lieu of the
70
> > Bq/g.
> > 3. You may use the new A1 and A2 values for classification of your
> > radioactive material shipment.
> > 4. You may use the new "fissile label" and associated CSI, criticality
> > safety index for fissile material shipments.
> > 5. You should be careful in using the Curie values in the A1, A2, exempt
> > concentration and exempt consignment tables, since the calculated values
> > in
> > the tables have been rounded and not truncated. Using the Curie values
> > you
> > may inadvertently exceed the prevailing Bq activity limits which are the
> > governing values.
> > 6. When using the exempt consignment value note the definition of
> > "consignment."
> >
> > Roy A. Parker, Ph.D.
> > roy@royparker.org
> > Tel: 225-924-1473
> > Fax: 225-924-4269
> >
> > ************************************************************************
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> >
> >
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