RE: Dot reg. questions (new rule)

[wyd@ornl.gov (Dana Willaford)]

I am very familiar with this rule and can offer you the following:

"172.310 for TI>10, the label category reads "Yellow-III (Muust be
shipped under exclusive use provisions)".  Does this mean that
these words must appear on the Yellow III label? "

Answer:  The requirement for TI>10 to be shipped with Y-III label, under
exclusive use is not new, and existed under the old regulations as well,
however the requirement was not stated in 172.403,(Label Table) as it is
now.  The notation for exclusive use is required on the shipping paper,
under 172.203(d)(10).  The only notations to be shown on RAM labels are the
activity and contents lines, and the TI for Y-II and Y-III labels.

"172.803 required dosimetry for occupationally exposed hazmat
employees if they exceed the 200 TI criteria.  But for fissile
controlled shipments the TI is artificially inflated as a way to
limit the number of packages per shipment.  This then trips the
monitoring requirement despite the fact that the radiation level
is nil.  Is there any way around this, i.e., to avoid having to
needlessly issue dosimeters?"

Answer: DOT's original intent was to have the 200 TI threshold based upon
the radiological TI, rather than the criticality TI, which you accurately
stated can be artificially high. There is not a current change planned to
amend this section, however, the effective date is not until 10/1/97, so
there is still some time to try to influence this.  However, in the interim,
if you are going to try to implement this section early, you may try to meet
172.803(ii).  If you have existing data to support not exceeding the 500
mrem/yr, this would probably be easier.

"173.457, for shipments with a TI>10, requires meeting 173.441(a) and (b).
...  The (b) requirement obviously has meaning for used fuel shipments.
Does it impact power reactor fresh fuel shipments?"

Answer: The 173.457 section more or less is the same as the old Fissile
Class III requirements.  Fresh fuel is not in this category, and is often
shipped as LSA.

Dana M. Willaford, NRRPT
DOE/OR, SE-33
423-576-5338