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Re: DOT Applicability
This question has bedeviled us for a while as well. In the end we
gave up & designed & had Type-A testing done for several packagings.
(They passed!) We have had the same response from our Agreement
State regulators (Ill. Dept. of Nuc. Safety) as the NRC as to the
"contiguous facility" concept, i.e., that the state did not intend
to enforce DOT regs. for transport on our campus. This, however,
left several questions unanswered, namely, would DOT enforce their
regs for such transport? Or, would the Ill. State police or the
Chicago police decide to enforce those regulations? The IDNS
assurances did not address these concerns. If I were to see a similar
statement on enforcement policy from DOT on transport around a campus,
I would be more comfortable. Also, wasn't someone at NIH convicted
of criminal charges a couple of years ago for transporting RAM around
that campus in the trunk of his car?
___________________________________________________________________
Don Jordan Tel. (773) 702-6299
Office of Radiation Safety Fax 702-4008
The University of Chicago email: don@radpro.uchicago.edu
1101 East 57th Street, Room 11
Chicago, Illinois 60637
-- Any opinions are the author's --