Re: Isotope Transfer Documentation Requirements

[LIPTONW@detroitedison.com]

You stated:  
 
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 
 
An alternative to 2 license amendments would be to request a waiver, under 
10CFR71.5(b).  It seems that there's a good case for a waiver, here. 
 
If this is not feasible, it seems that it would not be too difficult to comply 
with DOT requirements.  The most difficult part would be obtaining a suitable 
package, but this would be a one time event, unless you have a wide variety of 
materials.  The package could be reused.  The shipping papers would serve as 
your material accountability documentation, which you would need whether or 
not you comply with DOT requirements. 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com