Re: Isotope Transfer Documentation Requirements

[David Scherer <scherer@uiuc.edu>]

As someone has pointed out, if the transfer is completely indoors, DOT
rules do not apply.  However, someone else has pointed out that NRC imposes
the rules anyway.  (Agreement states impose them, too, since this is an
item of compatibility.)  The only way out would seem to be a license
amendment for both institutions to exempt your inter-institutional
transfers from DOT requirements.  The circumstances seem to make the
exception very reasonable.

Good luck.

Dave Scherer
scherer@uiuc.edu

>Radsafers,
>
>We're looking for a way to legally yet simply transfer radioactive material
>between our facility and an adjacent but separately licensed facility.  We
>- the Medical College of Georgia - are licensed by the State; they - the
>Augusta Veterans Administration Hospital - are licensed by the NRC. 
>The facilities are physically connected and we, by contract, supply rad
>safety services to the VA.   For example, frequently it would be
>convenient to count a source in one facility for use in the other.  Since
>the material always remains within the confines of one or the other
>facilities, we may not have to comply with DOT regulations.  If anyone
>has come up with a simple way to comply with rad mat transfer
>requirements for a similar situation, we'd very much appreciate hearing
>from you.
>
>Reply to:
>
>Bill Stephany
>Assistant RSO
>Medical College of Georgia
>fiss.bstephan@mail.mcg.edu