Re: Survey Outgoing RAM

[LIPTONW@detroitedison.com]

You wrote: 
 
  Do Specifically licensed Companies that distribute General Licensed or 
Exempt quantity items have to monitor and/or wipe these packages before they 
are distribulted ???   
 
   49 CMR 173.475(i) does not differentiate between transfered, LQ, TYPE A, 
TYPE B, GL, nor exempt quantities... Therefore is it best to assume that all 
outgoing distributed RAM have to be metered and wiped ???? 
 
 
Thanks, 
 
Greg Moriarty 
 
It is important to keep in mind that receipt/possession and transportation
of 
ram are 2 separate sets of regulations.  Whether a package of radioactive 
material is exempt, generally licensed, or specifically licensed under NRC 
regulations (10 CFR) has no effect on the requirements of DOT (49 CFR). 
Thus, 
the dose rate and removable contamination requirements of 49 CFR must be met 
no matter what the licensing status under 10 CFR.  Conversely, a package of 
radioactive material may be exempt from transportation regulations, if it is
< 
2 nCi/g of essentially evenly distributed activity, yet not be free 
releaseable under NRC regulations. 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com