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Re: RE: Transportation of RAM to be used in a remote location
Even if this weren't illegal, it's one of the dumbest things I've ever heard.
Consider 10CFR71.5:
(a) Each licensee who transports licensed material outside the site of usage,
as specified in the NRC license, or where transport is on public highways, or
who delivers licensed material to a carrier for transport, shall comply with
the applicable requirements of the DOT regulations in 49 CFR parts 170 through
189 appropriate to the mode of transport.
...
(b) If DOT regulations are not applicable to a shipment of licensed material,
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 subject to DOT regulations.
The key considerations are whether the material either:
(1) leaves the site covered by the applicable license, or
(2) travels on a "public highway".
In this case, "public highway" would be any road which is accessible to the
public, no matter who owns it.
It still bothers me a lot that so many of my colleagues, whom I assume are
otherwise skilled and knowledgable people, apply their creativity to looking
for loopholes in the regulations rather than to developing practical and cost
effective means of compliance.
The opinions expressed are strictly mine.
Here's to a risk free world, and other fantasies.
Bill Lipton
liptonw@detroitedison.com
My understanding is that the DOT regs. are for "Motor vehicles" ... So if you
have them walk it or take their bike then these sets of regs. don't apply.
Please respond if you feel this is an incorrect interpretation.
William A. Lorenzen
Children's Hospital
Boston, MA
617-355-7516
lorenzen_w@a1.tch.harvard.edu