Re[2]: DOT vs NRC/DOE Regs

[rodney_bauman@wssrap-host.wssrap.com]

Someone wrote:

"Is the exception in 10 CFR 20.1903(a) [less than 8 hours, licensee controlled
area, someone continuously present] any help?  If not, what changes to the rule
would be necessary to make it useful in your example?"

Reply:
There is no guarantee that the truck will leave within 8 hours after being
prepared for shipment (e.g., sometimes they won't leave until the next day). 
Simply extending the time allowance will not solve the problem.

One way to prevent this situation from occurring would be to create a new
exception to the posting requirements of 10CFR20 and 10CFR835.  The exception
would apply to "Radiation Area" posting requirements and areas required to be
posted for "Radioactive Material(s)."  It would only apply to such areas created
solely as a result of a radioactive material shipment which is fully prepared
for shipment in accordance with applicable shipping regulations.

Disclaimer, I've put minimal thought into this response (from a "big picture"
point of view).  I'm sure this type of exception has been evaluated by others in
the past and found to be unacceptable for some logical reason (e.g., potential
unposted high dose rates on a licensee's property - which is unacceptable).

Rodney Bauman, CHP, RRPT
Senior Health Physicist
Weldon Spring Site Remedial Action Project
Rodney_Bauman@wssrap-host.wssrap.com

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