On-Site Transport of Radwaste

[Mack Richard <MRICHARD@WPO.IUPUI.EDU>]

Radsafers:

Is it just me (and my staff) or doesn't it seem ridiculous that we must
package, label, and manifest a container of radwaste to transport it
less than a mile on our campus in the same way as if we were going to
ship it across the country?  As I read it, that is exactly what 10 CFR
71 says and my friends at the NRC have verified same.

After much discussion, we decided to request "alternative procedures"
for this transport on our campus as suggested in 10 CFR 71.  This was
sent in along with the customary amendment fee.  We have not received
anything official from the NRC; however, we do know our request was
forwarded to NRC headquarters for a "technical assistance request
(TAR)."  

Based upon a discussion with one of the NRC Region III licensing staff,
it was his opinion that our request has a relatively unlikely chance of
being approved by NRC headquarters.  He says the NRC does not like the
"E" (exempt) word when it comes to regulations.  Even though we avoided
using the "E" word (we used alternative procedures), he suspects that it
boils down to the same result.

His reasoning is that the NRC will take the approach that many other
licensees out there are meeting these transport regulations and as such
our request is not justified.  He further opined that this is a
precedent setting amendment and if they grant our request, the amendment
flood gates will open and they will be inundated with similar requests
from other licensees.

He did suggest that we "take the bull by the horns" and petition the NRC
for rulemaking with respect to these transport requirements.  We are
seriously considering doing so.  We wanted to let you radsafers know
just in case you would want to comment (hopefully, in a favorable way). 
Any comments or suggestions are appreciated.

Mack L. Richard, M.S., R.S.O.
mrichard@wpo.iupui.edu
Phone:  (317) 274-0330    FAX:  (317) 274-2332