Re: On-Site Transport of Radwaste

[LIPTONW@detroitedison.com]

The question is not the distance or even the transfer of ownership, but 
whether you are traversing a public highway.  In this case, a "public highway" 
would be a highway that is accessible to the general public, even if privately 
owned, as may be the case on a campus.  If you are exposing the public to your 
shipment, then DOT rules generally apply.   
 
It is worthwhile to look at the EPA's definition of "on-site," which applies 
to hazardous waste transfers.  This is defined, in 40 CFR 260.10 as: 
 
"On-site means the same or geographically contiguous property which may be 
divided by public or private right-of-way, provided the entrance and exit 
between the properties is at a crossroads intersection, and access is by 
crossing as opposed to going along, the right-of-way.  Non-contiguous 
properties owned by the same person but connected by a right-of-way which he 
[*] controls and to which the public does not have access, is also considered 
on-site property." 
 
*(It should be noted that 40 CFR 260.3 states:  "As used in Parts 260 through 
265 and 268 of this chapter:  (a) Words in the masculine gender also include 
the feminine and neuter genders;...") 
 
In other words, if you can reach the other building by crossing the public 
highway at right angles, the two buildings may be considered to be the same 
site, and waste transfers do not require a hazardous waste manifest.  However, 
if you have to go along the highway for any distance, then the buildings must 
be managed as separate sites, and a hazardous waste manifest is required for a 
transfer, unless the highway is a private highway which does not allow public 
access. 
 
Bill Lipton 
The opinions expressed are strictly mine. 
Here's to a risk free world, and other fantasies.

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• To: Multiple,recipients,of,list,radsafe@romulus.ehs.uiuc.edu
• Subject: Re: On-Site Transport of Radwaste
• From: "radsafe@romulus.ehs.uiuc.edu" <radsafe@romulus.ehs.uiuc.edu>
• Date: 04 Nov 96 15:13:25
• Reply-to: radsafe@romulus.ehs.uiuc.edu

> Date:          Mon, 4 Nov 96 14:07:32 -0600
> From:          Mack Richard <MRICHARD@WPO.IUPUI.EDU>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       On-Site Transport of Radwaste

> 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.
>...
> Any comments or suggestions are appreciated.

	Hmmm.  Just what is the dividing line  as far as transportation distance?

	If you have a filled drum of waste in the RS storage area and want to 
	move it to the back of the storage area and bring up another empty drum,
	do you  have to do the paperwork shuffle on THAT move?  What if you
	are moving the drum across the hall? Up two floors? 

	Is  not the dividing line not supposed to be distance, but the point at which
	control of the package transfers  from one person or group to another? 
	I'd  fight it, but then I've seen worse interpretations from some over-
	zealous/naive administrators.

Frank R. Borger - Physicist       ___       "The only problem with being 'over
Michael Reese - U of Chicago   |___        the hill,' is that you tend to
Center for Radiation Therapy   |   |_) _    pick up speed on the downgrade!"
net: Frank@rover.uchicago.edu    |  \ |_)   - Erik Von der Blauen
ph: 312-791-8075 fa: 791-3697        |_)  

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