DOT applicability

[Luke.I.Mccormick@MRD01.usace.army.mil]

It seems to me that DOT applicability is applied to all NRC
licensed RAM through 10 CFR 71.5(b) "If DOT regulations
are not applicable to a shipment of licensed material by rail,
highway, or water because the shipment or the
transportation of the shipment is not in interstate or foreign
commerce, or to a shipment of licensed material by air
because the shipment is not transported in civil aircraft, the
licensee shall conform to the standards and requirements of
the DOT specified in paragraph (a) of this section to the
same extent as if the shipment or transportation were in
interstate or foreign commerce or in civil aircraft. A request
for modification, waiver, or exemption from those
requirements, and any notification referred to in
those requirements, must be filed with or made to the
Director, Office of Nuclear Material Safety and Safeguards,
U.S. Nuclear Regulatory Commission, Washington, DC
20555."
Note that this does not include movement within your
facility. In a call to NRC, it was explained that movement
within a facility (med school and hospital located on
contiguous city blocks), including on the public roads, as
long as the roads were 'within the facility' was not regulated,
however another med school and the hospital, which were
on opposite sides of the interstate highway were considered
two facilities (they were licensed separately, under some
specific licenses and together under another specific
license) and transport between them is regulated.

Additionally most every agreement state I've seen has a
similar statement.

Luke Mccormick
luke.mccormick@mrd01.usace.army.mil