ML18205A679
| ML18205A679 | |
| Person / Time | |
|---|---|
| Site: | 03035668 |
| Issue date: | 07/18/2018 |
| From: | Michael Reichard NRC Region 1 |
| To: | Davis S US Dept of Defense (DOD) |
| References | |
| 602208 | |
| Download: ML18205A679 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD. KING OF PRUSSIA, PA 19406-2713 July 18, 2018 Sherry Davis, Director, ESOH Office Department of Defense Defense Threat Reduction Agency 8725 John J. Kingman Road Fort Belvoir, VA 22060-6201
SUBJECT:
DEPARTMENT OF DEFENSE, DEFENSE THREAT REDUCTION AGENCY, RESPONSE OF NOTIFICATION, MAIL CONTROL NO. 602208
Dear Ms. Davis:
This is in reference to your letter dated January 12, 2018, discussing your understanding of applicable transportation requirements.
Your discussion distinguishes between the terms "shipping," which you define as pertaining to use of a third party shipper, and "transporting," which you define as pertaining to movement of items by Defense Threat Reduction Agency (DTRA) staff. Applicable NRC and DOT regulations do not necessarily make this distinction and may use the terms interchangeably.
You discuss the distinction between transportation and use in a moving vehicle, which was pertinent to recent inspection, 03035668/2017002.
You and many licensees use radioactive materials in moving vehicles.
We believe that this is the primary topic of your letter. In the example you reference in paragraph four of your letter, you describe an authorized use under your NRC license. The activity involves material not in a DOT shipping container, because it is in use for training, exercises, radiation equipment validation, or other similar licensed activities.
In this example, you would be using the material for its licensed purpose and is permissible.
What distinguishes this from transportation is that you would not have the material in a moving vehicle with the intent of relocate it, but rather to perform an authorized activity under your license. If you have any questions regarding this matter, please contact me at 610-337-6945 or via electronic mail at michael.reichard@nrc.gov.
S. Davis Your cooperation is appreciated.
License No. 45-25551-01 Docket No. 03035668 Mail Control No. 602208 cc: Brian Stroh, Radiation Safety Officer 2 Michael Reichard, Health Physicist Commercial, Industrial, R&D and Academic Branch Division of Nuclear Materials Safety Region I S. Davis Your cooperation is appreciated.
License No. 45-25551-01 Docket No. 03035668 Mail Control No. 602208 cc: Brian Stroh, Radiation Safety Officer 2 Sincerely, Michael Reichard, Health Physicist Commercial, Industrial, R&D and Academic Branch Division of Nuclear Materials Safety Region I DOCUMENT NAME: G:\WBL Documents\WBL License Cover Letter\L45-25551-01.602208.docx
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