Re: Ram in Transit

[TSNKW@ccmail.ceco.com]

     One reference for "guidance" on this subject is the NRC's Q & A Set 
     for the Revised 10 CFR 20.  Specifically, Question 53 deals both with 
     the issue of posting and labelling of shipments.  The pertinent parts 
     are:
     
     "10 CFR 20.1905(d) exempts this package from the labeling 
     requirements of 10 CFR 20.1904 (a) ...
     
     ... the posting requirements remain in effect until the transporter 
     has actually taken possession of the package and is starting to 
     transport it."
     
     This issue comes up a lot at nuclear power plants since radwaste 
     shipments involve a lot of final paperwork and quality control 
     inspections after a tractor trailer is loaded, properly labelled, 
     and placarded, etc.  There may a several hour delay between when the 
     truck appears ready to go and when shipment papers are actually 
     signed off.  As indicated above, the NRC considers their licensees 
     subject to normal posting requirements (radioactive material, 
     radiation area, high radiation area, as applicable) until such time 
     as the transport actually begins.  Then, NRC regulations no longer 
     apply "during shipment" as previous commenters have indicated.
     
     Also, note that 10 CFR 20.1601 (e) provides a limited exemption to 
     access control requirements for high radiation areas where 
     radioactive materials are present due to their preparation for DOT 
     shipment.  This exemption is not to the posting requirements of 10 
     CFR 20.1902, again for where a package might be awaiting final 
     inspection or sign-off for a departure.
     
     Kit Weaver
     tsnkw@ccmail.ceco.com
______________________________ Reply Separator _________________________________
Author:  radsafe@romulus.ehs.uiuc.edu at INTERNET 
Date:    12/14/95 7:08 PM
     
     
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?