Re: ram in transit

[jgbarnes@ix.netcom.com (JAMES BARNES)]

I guess I could have been a bit less cryptic in my previous message.

The "in transit" statement has special significance to an NRC licensee 
(especially in the "old" pre-1994 days) as it exempted him/her from having to 1) 
post a room or area just because it had RM in it, 2) label the material with a 10 
CFR 20 label (if it was labeled in accordance with DOT labeling schemes, and 3) 
erect and maintain high radiation area controls in the area where the material 
was stored (20.204(d) et. al.).  This was convenient as one didn't have to worry 
about the 10 CFR 20 niceties while one was assembling shipments on licensee 
property prior to the shipment.

The "new" 20 curtailed the scope of the exemption, as I noted in my note.  You 
still are exempt from labeling and high rad area controls (for a period of days), 
but you must post.

The dividing line between NRC and DOE regs is a bit nebulous, but generally my 
experience has been that DOT regs become effective when you start staging for and 
loading the transport vehicle (this is interpretative; I can't cite a clear reg 
on this, but it seems to agree with the general approach taken in the 
transportation industry).  I seem to recall that "in transit" was defined in DOT 
regulations dealing with the contractual relationships between a shipper and a 
consignor.  It was not limited to nuclear transport.

A previous commentor mentioned 49 CFR 173.447, "Storage incident to 
transportation-general requirements."  This regulation uses the transport index 
as the criterial of interim storage on docks, warehouses, vehicles, etc.  TI can 
also depend on curie content of the package for certain isotopes.

To my knowledge, what you described is not ancient history.  Word is that DOT is 
intending to implement some new regulations in order to come into compliance with 
international standards, but I'm not sure where that stands.

As an aside, if one is anticipating doing some shipping, he/she would be very 
well advised to take a review course so that you can understanding the structure 
and philosophy of the regs.  Once you understand what the writers were thinking, 
the regulations become fairly easy to decipher.

Jim Barnes, CHP
RSO
Rocketdyne Division; Rockwell Aerospace
---------------------------------------
You wrote: 
>
>  In a previous life (pre '78) I was involved with shipping radionuclides.
>Trucks transporting the boxes to the airport had to be labeled on the sides
>and back.  I am still seeing trucks with such labels, mainly soil testing
>operations.  There was a limit on the number of transport indexes that could
>be loaded on a truck without meeting special requirements. If I remember
>correctly the TI for a package was the radiation level at 1 meter from the
>package.  The maximum alowed values were 200 mr/hr on contact and 10 mr/hr
>at 1 meter.  Is this now ancient history?
>