[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: Isotope Transfer Documentation Requirements
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