[ RadSafe ] Re: Exempt Quantity source shipments

Luke McCormick mccormickl at hotmail.com
Thu Jul 23 14:30:21 CDT 2009

 Except as provided in paragraphs (c) through (e) of this section, any person is exempt from the requirements for a license set forth in section 81 of the Act and from the regulations in parts 30 through 34, 36, and 39 of this chapter to the extent that such person receives, possesses, uses, transfers, owns, or acquires byproduct material in individual quantities, each of which does not exceed the applicable quantity set forth in § 30.71, Schedule B.


So you do not need a license

No person may, for purposes of producing an increased radiation level, combine quantities of byproduct material covered by this exemption so that the aggregate quantity exceeds the limits set forth in § 30.71, Schedule B,


So you can combine quantities as long as you are not doing it for the stated purpose.

Luke McCormick

> To: radsafe at radlab.nl
> From: roseb at gdls.com
> Date: Thu, 23 Jul 2009 15:08:02 -0400
> Subject: [ RadSafe ] Re: Exempt Quantity source shipments
> George:
> >It is not enough that the material is of exempt quantity, you MUST be 
> licensed to transfer even exempt quantity, but not to receive it.
> Per 10CFR30.18, the above statement might not be correct.
> § 30.18 Exempt quantities
> http://www.nrc.gov/reading-rm/doc-collections/cfr/part030/part030-0018.html
> >There are also limits as to how many eqempt quantities may be shipped in 
> a single package (10).
> What is the DOT, NRC, IATA, IMDG basis for this limitation?
> If the sources do not meet the definition of Radioactive Material in 
> 49CFR173.403 due to the both activity concentration AND the total activity 
> in the 
> consignment NOT exceed the values specified in the table in 49CFR173.436, 
> and are therefore not sufficiently radioactive to be subject to the HMR, 
> why would there be a limitation on how many of the sources can be shipped 
> under USDOT regs & jurisdiction?
> Henry
> Boyd H. Rose, CM, CIH, CHMM
> Sr. Safety and Environmental Engineering Specialist
> Corporate Radiation Safety Officer
> General Dynamics Land Systems
> 38500 Mound Road
> Mail Zone 436-10-75
> Sterling Heights , MI 48310-3269
> Tel: 586 825 4503
> Fax: 586 825 4015
> E-mail: roseb at gdls.com
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