[ RadSafe ] SEALED SOURCE DISPOSAL

[Robert Young]

Ken,

Likewise, I am not as fluent with the 'ins and outs' of NRC's regulations as I am Tennessee's, but these devices are not exempt in Tennessee. I am not sure about Wisconsin, but Paul Schmidt is the head of the Wisconsin radiation control program and will know. His telephone number is 608-267-4792.

I read that section you referenced and from first reading I could agree, except that the Sealed Source & Device Sheet for this device (MA-0399-D-104-G) indicates distribution to General Licensees. Upon further review it seems that this device which is now manufactured & distributed by GE Homeland Protection, Inc. out of Massachusetts was previously manufactured & distributed by GE Ion Track with a history: formerly Ion Track Instruments, Inc. (ITI), GE Ion Track; see also iTi Qualitek, Inc. also out of Massachusetts. This was probably at a time before Massachusetts became an Agreement State. You are correct that the previous Sealed Source & Device Sheet (NR-0399-D-802-E) indicates that the unit was authorized for exempt distribution, but for some reason this has changed with the Sealed Source & Device Sheet issued by the State of Massachusetts. Agreement States cannot authorize exempt distributions of devices covered by NRC regulations and this may be the reason that the distribution group was changed from Exempt to General.

I am sorry, I cannot send you the Sealed Source & Device Sheet I reference, but NRC considers these as a sensitive document of one kind or another, and therefore they are not publically available. You might however get a copy from GE Homeland Protection, Inc. since they are the manufacturer.

Sincerely,

Robert Young, HPS-II
(615) 532-0384
Tennessee Division of Radiological Health

PS: My comments are mine and mine alone. They may or may not be reflective of those of my employer.


>>> "Peterson, Ken" <KPeterson at MarinetteMarine.com> 5/24/07 11:02:11 AM >>>
Robert,

This is not my area of expertise, and I would defer to the knowledge
base of the group, but I was under the impression the device was exempt
from licensing under 10CFR30.20.  

Sincerely,

Ken Peterson
Safety/Environmental Engineer
Littoral Combat Ship Project
Marinette Marine
1600 Ely St.
Marinette, WI  54143
(715-735-9341 x6157
www.lmlcsteam.com 
 


-----Original Message-----
From: Robert Young [mailto:Robert.Young at state.tn.us] 
Sent: Thursday, May 24, 2007 10:48 AM
To: Peterson, Ken; radsafe at radlab.nl 
Subject: Re: [ RadSafe ] SEALED SOURCE DISPOSAL


Ken,

I beg to differ with you, because unless the Device Distribution
Authorization for the "GE Vaportracer Detector" has been changed or
modified lately, then this device can only be transferred as a General
License Device (GLD). I would agree that the GLD is not tracked by
Government Radiation Control Agencies in the USA (NRC, Agreement States,
etc.) like an Industrial Radiography Source, but at the same time, this
device is NOT exempt either (like a common Smoke Detector).

Sincerely,

Robert Young, HPS-II
(615) 532-0384
Tennessee Division of Radiological Health

PS: My comments are mine and mine alone. They may or may not be
reflective of those of my employer.

>>> "Peterson, Ken" <KPeterson at MarinetteMarine.com> 5/24/07 10:16:32 AM 
>>> >>>
Dear RadSafe List:
 
In the USA, there seems to be a new proliferation of explosive detectors
that use a sealed source for ionization.  I am purchasing a GE
Vaportracer Detector that contains a 10mCi Ni-63 sealed source.  While I
have determined that the device is exempt from licensing and leak
testing requirements, I am worried about disposing of the device at the
end of it's service.   What are the disposal requirements for sealed
sources?  It seems obvious to me that this equipment can't go to regular
landfill and must go to a disposal site for Low Level Radioactive Waste?
 
Any advice would be appreciated.
 
Ken Peterson
Safety/Environmental Engineer
Littoral Combat Ship Project
Marinette Marine
1600 Ely St.
Marinette, WI  54143
(715-735-9341 x6157
www.lmlcsteam.com 
 
 
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