Re: ram in transit

["ALDEN N TSCHAECHE" <XAT@inel.gov>]

The DOT regulations for transport of radioactive material were
constructed so that no controls, posting, marking or anything else were
to be needed for protection of people in the transportation industry so
long as the DOT regulations are  followed. It shouldn't matter how many
RAM packages are stored in one location. The dose to people around them
will be acceptable without monitoring or recording. Any DOT/NRC people
out there should be able to verify this statement. Al Tschaeche
xat@inel.gov

*** Reply to note of 12/15/95 09:11

From: Edwin Wright
To: RADSAFE --INELMAIL RADSAFE

Subject: Re: ram in transit
>
>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