NRC Regulatory Issue Summary: Applicability of Transportation Requirements During Movement of Radioactive Material Within a Temporary Jobsite

This U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) clarifies the regulatory framework governing the movement of radioactive materials within the boundaries of a temporary jobsite, such as construction sites, well-logging operations, or industrial radiography locations. The core question addressed is whether NRC regulations (10 CFR Parts 20 and 71) or U.S. Department of Transportation (DOT) regulations (49 CFR) apply when licensed radioactive material is moved within a defined temporary work area rather than on public roads or highways. The NRC's position is that when radioactive material is moved solely within the confines of a temporary jobsite — without entering public transportation infrastructure — the movement is generally not considered 'transportation' under DOT rules. In such cases, NRC licensee requirements continue to apply, including proper storage, radiation protection, and handling procedures under 10 CFR Part 20 and applicable license conditions. Licensees are reminded that even within a temporary jobsite, radiation safety protocols must be maintained at all times. This includes proper shielding, signage, personnel monitoring, and accountability for sealed sources or other licensed material. The distinction between intra-site movement and transport on public roads has direct implications for packaging, labeling, and placard requirements. This guidance is intended to reduce regulatory ambiguity for NRC licensees operating in field environments, ensuring they understand which agency's rules govern their activities depending on whether movement occurs on or off a defined temporary work area.

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