[ RadSafe ] SEALED SOURCE DISPOSAL

[Cindy Bloom]

Imprecise use of regulatory terms is leading to this 
confusion.  Radioactive material can be exempt (from some, or all rules and 
regulations, and the exemption is sometimes noted on the source or device), 
subject to general license requirements (in this case the manufacturer 
and/or regulator define the conditions of 
use/storage/transfer/disposal/etc., which are typically either provided in 
the regulations, on the source or device, and/or in documents provided with 
the source), or subject to specific licensing requirements.  The only time 
that I think a specific license might be required for an item that is 
typically subject to general license requirements, is when the possessor 
decides to use the source for something other than stipulated by the 
general license.

I have a vague recollection of reciprocity or some such thing between the 
States and the NRC regarding such matters (to become an Agreement States, 
e.g., to regulate byproduct and source material,  States have to have rules 
and regulations that are consistent with the NRC).  But it never hurts to 
check with your local regulators.  Transportation regulations might also 
require special packaging, package labeling or bills of lading, if the 
device is transported out of the facility.  The manufacturer's are usually 
good sources for much of this information.

At 11:02 AM 5/24/2007 -0500, Peterson, Ken wrote:
>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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