Re: Isotope Transfer Documentation Requirements

[amattox@mbl.edu (Andy Mattox)]

 LIPTONW@detroitedison.com wrote:


>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.

10CFR71.5(b) does not seem to apply under circumstances described in
original post. It extends DOT regs to certain rail, highway, water and air
shipments but not movement within interconnected facilities. I don't see
any transportation concerns at all. Issue seems to center on controlling
frequent transfers between licensees and movements on/off the premises
covered by respective licenses. I suggest entire complex should be listed
on each license and "dual citizenship" established for any personnel who
are handling materials which appear on both licenses.