Re: ram in transit

[elw1@ix.netcom.com (Edwin Wright)]

>
>It's my understanding that radioactive material which is "in transit", 
and is
>marked and labeled in accordance with DOT requirements does not 
require
>10CFR20 postings.  However, I can't find a regulatory basis for this.  
Does
>anyone know where this is covered in regulations or regulatory 
guidance?
>
>


Since NRC does not have direct jurisdiction over transportation you 
will not find any reference that specifically states this. DOT 
regulations do address maximum TI's and limitations on dose rates, but 
do not contain specific posting requirements.

My problem with this situation is that many shipping terminals usually 
have only one storage area for hazardous materials. Because of the 
volume of material handled, these areas can easily contain excessive 
amounts of radioactive materials and present an unmonitored 
radiological hazard. Other hazardous material packages are usually 
mixed in with the radioactive packages. A real problem if an 
incident/accident occurs.

At a fixed facility, such as a terminal, OSHA may have jurisdiction. 
They have basically copied the NRC regulations concerning radiation 
exposures, etc. Although my experience to date is that OSHA may not be 
adequately staffed to enforce their radiation rules.

Edwin L. Wright, CHP

elw1@ix.netcom.com