[ RadSafe ] Re: radsafe Digest, Vol 211, Issue 2
Lazarre, Chuck
chuckl at BaylorHealth.edu
Wed Sep 2 15:04:08 CDT 2009
----- Original Message -----
From: radsafe-bounces at radlab.nl <radsafe-bounces at radlab.nl>
To: radsafe at radlab.nl <radsafe at radlab.nl>
Sent: Wed Sep 02 15:03:29 2009
Subject: radsafe Digest, Vol 211, Issue 2
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_______________________________________________
Today's Topics:
1. RE: Mobile [cellphones] towers threatening honey beesin
Kerala', Press Trust of India, PTINews.com (Dan W McCarn)
2. RE: Seeking exempt quantity sources donation.
(Johanning, Jeffrey R.)
3. RE: Seeking exempt quantity sources donation. (Bray, Linda G.)
4. Re: Scientist joins effort to repeal nuclear-plant ban
(Otto G. Raabe)
5. RE: Seeking exempt quantity sources donation. (Glenn R. Marshall)
6. RE: Seeking exempt quantity sources donation. (Cary Renquist)
7. RE: Seeking exempt quantity sources donation. (Glenn R. Marshall)
8. Assistant RSO position (khelm924 at aol.com)
9. Re: Seeking exempt quantity sources donation. (Geo>K0FF)
----------------------------------------------------------------------
Message: 1
Date: Tue, 1 Sep 2009 10:38:05 -0600
From: Dan W McCarn <hotgreenchile at gmail.com>
Subject: RE: [ RadSafe ] Mobile [cellphones] towers threatening honey
beesin Kerala', Press Trust of India, PTINews.com
To: "'Glenn R. Marshall'" <GRMarshall at philotechnics.com>, 'Franz
Sch?nhofer' <franz.schoenhofer at chello.at>, "'DougHuffman'"
<doug.huffman at wildblue.net>, "'Dutch Radsafers'" <radsafe at radlab.nl>
Message-ID: <571B1601F121483490C3265627A64FBB at DocHolidayII>
Content-Type: text/plain; charset="iso-8859-1"
Dear Group:
In deference to Franz, I remember the news reports about isotopic
discrepancies downwind from Zwenttendorf suggesting that it was the reactor
that caused them... (Zwenttendorf was the Austrian reactor that was never
fueled) The result of another fear-mongering hoax.
Dan ii
--
Dan W McCarn, Geologist
7 Likely Place
Santa Fe, NM 87508-5938
+33.(0).6.47.86.05.25 (Mobile - France)
+33.(0).9.70.44.04.03 (Skype - France)
+1-505-240-6872 (Skype - New Mexico)
HotGreenChile at gmail.com (Private email)
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Glenn R. Marshall
Sent: Tuesday, September 01, 2009 08:26
To: Franz Sch?nhofer; 'DougHuffman'; 'Dutch Radsafers'
Subject: RE: [ RadSafe ] Mobile [cellphones] towers threatening honey beesin
Kerala', Press Trust of India, PTINews.com
Aha! So there is a danger associated with miniscule levels of radiation,
and the danger is this: Hearing or reading the word "radiation" causes a
marked increase in stupidity. Perhaps I can get some stimulus funding to
investigate this matter........
Glenn Marshall
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Franz Sch?nhofer
Sent: Tuesday, September 01, 2009 10:05 AM
To: 'Doug Huffman'; 'Dutch Radsafers'
Subject: AW: [ RadSafe ] Mobile [cellphones] towers threatening honey bees
in Kerala', Press Trust of India, PTINews.com
Doug,
Thank you so much indeed for forwarding this article, which explains the
real truth about bees slowly vanishing from nature. I would have believed
that in Kerala they die from the much elevated natural radiation background
well known. In Europe they die from Varroa or pesticides. Until now I have
not heard about mobile phones and towers, but I am sure that some
environmental groups will be happy to investigate this if enough funding is
provided!
I remember the news in Austrian papers after the TMI accident, where it was
stated, that birds were falling dead from the sky in Harrisburg and
vicinity. Not to talk about monster trees and plants having been seen near
Chernobyl.
This is another independent "confirmation" of the risks of radiation in
whatever form it comes.
I hope everybody knows my attitude to ridicule ridiculous "scientists".
Best regards,
Franz
Franz Schoenhofer, PhD
MinRat i.R.
Habicherg. 31/7
A-1160 Wien/Vienna
AUSTRIA
-----Urspr?ngliche Nachricht-----
Von: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] Im Auftrag
von Doug Huffman
Gesendet: Montag, 31. August 2009 20:41
An: Dutch Radsafers
Betreff: [ RadSafe ] Mobile [cellphones] towers threatening honey bees in
Kerala', Press Trust of India, PTINews.com
http://www.ptinews.com/news/256707_Mobile-towers-threatening-honey-bees-in-K
erala
N Muraleedharan
Thiruvananthapuram, Aug 31 (PTI) Mobile towers are posing a threat to
honey bees in Kerala withe electromagnetic radiation from mobile towers
and cell phones having the potential to kill worker bees that go out to
collect nectar from flowers, says a study.
A plunge in beehive population has been reported from different parts of
Kerala and if measures are not taken to check mushrooming of mobile
powers, bees could be wiped out from Kerala within a decade,
environmentalist and Reader in Zoology, Dr Sainudeen Pattazhy says in
his study.
In one of his experiments he found that when a mobile phone was kept
near a beehive it resulted in collapse of the colony in five to 10 days,
with the worker bees failing to return home, leaving the hives with just
queens, eggs and hive-bound immature bees.
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------------------------------
Message: 2
Date: Mon, 31 Aug 2009 12:38:41 -0700
From: "Johanning, Jeffrey R." <JEFFREY.R.JOHANNING at saic.com>
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
To: <radsafe at radlab.nl>
Message-ID:
<FE15E05B896BA240BF363CB814777965DF5DB4 at 1655-its-exmp01.us.saic.com>
Content-Type: text/plain; charset="us-ascii"
I'm just curious. I had worked on an NRC "E" license a few years ago
and my memory maybe lost or things may have changed. I recall that the
"unlicensed" users of exempt quantities were not allowed to redistribute
them, only tear off the label and throw them away. (which doesn't make a
lot of sense either)??
Just curious of what the current rules are?
Jeffrey R. Johanning
Health Physicist V/RSO
Science Applications International Corp.
858-826-9725
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Geo>K0FF
Sent: Saturday, August 29, 2009 07:36
To: radsafe at radlab.nl
Subject: [ RadSafe ] Seeking exempt quantity sources donation.
Hello.
We are seeking unlicensed (schedule B quantities) exempt quantity sealed
sources, NORM and
"Becquerel Kits" for recycling into educational uses.
Contact me off list for shipping instructions or we can pick up larger
shipments if within driving distance of Oak Ridge, Las Vegas, or St.
Louis
This is an ongoing requirement. The sources will be used to help train
future RP's and in school demonstrations kits as appropriate.
EDUCATORS- contact me offlist if you have a need for one of our loaner
Rad Demo Kits.
George Dowell
New London Nucleonics Lab.
email:
GEOelectronics at netscape.com
TELCO 573-221-3418
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
------------------------------
Message: 3
Date: Wed, 2 Sep 2009 08:01:53 -0700
From: "Bray, Linda G." <LINDA.G.BRAY at saic.com>
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
To: "Johanning, Jeffrey R." <JEFFREY.R.JOHANNING at saic.com>,
<radsafe at radlab.nl>
Message-ID:
<FE15E05B896BA240BF363CB814777965DF638B at 1655-its-exmp01.us.saic.com>
Content-Type: text/plain; charset="us-ascii"
Jeff, they cannot redistribute. That has not changed. They can take it
places and use it, but not sell, uninstall, install, or redistribute.
This does actually make sense, because if they don't have the license,
they don't have the overhead of the tracking, and reports as to where
they were distributed etc. So it makes the process fall apart from that
perspective
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Johanning, Jeffrey R.
Sent: Monday, August 31, 2009 12:39 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
I'm just curious. I had worked on an NRC "E" license a few years ago
and my memory maybe lost or things may have changed. I recall that the
"unlicensed" users of exempt quantities were not allowed to redistribute
them, only tear off the label and throw them away. (which doesn't make a
lot of sense either)??
Just curious of what the current rules are?
Jeffrey R. Johanning
Health Physicist V/RSO
Science Applications International Corp.
858-826-9725
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Geo>K0FF
Sent: Saturday, August 29, 2009 07:36
To: radsafe at radlab.nl
Subject: [ RadSafe ] Seeking exempt quantity sources donation.
Hello.
We are seeking unlicensed (schedule B quantities) exempt quantity sealed
sources, NORM and
"Becquerel Kits" for recycling into educational uses.
Contact me off list for shipping instructions or we can pick up larger
shipments if within driving distance of Oak Ridge, Las Vegas, or St.
Louis
This is an ongoing requirement. The sources will be used to help train
future RP's and in school demonstrations kits as appropriate.
EDUCATORS- contact me offlist if you have a need for one of our loaner
Rad Demo Kits.
George Dowell
New London Nucleonics Lab.
email:
GEOelectronics at netscape.com
TELCO 573-221-3418
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
------------------------------
Message: 4
Date: Wed, 02 Sep 2009 08:33:05 -0700
From: "Otto G. Raabe" <ograabe at ucdavis.edu>
Subject: Re: [ RadSafe ] Scientist joins effort to repeal
nuclear-plant ban
To: "Cary Renquist" <cary.renquist at ezag.com>,<radsafe at radlab.nl>
Message-ID: <20090902153323.0FCF0FABD9A at mx.dcn.davis.ca.us>
Content-Type: text/plain; charset="us-ascii"; format=flowed
At 08:58 AM 9/1/2009, Cary Renquist wrote:
http://www.postbulletin.com/newsmanager/templates/localnews_story.asp?z=
16&a=413934
Political Notebook: Scientist joins effort to repeal nuclear-plant ban
8/31/2009 8:15:02 AM
A Rochester scientist is part of a new coalition pushing for the repeal
of Minnesota's ban on building new nuclear plants............
**************************************************
As we know, Rich Vetter is a board-certified health physicist, a past
president of the Health Physics Society, and a past Editor of the
Health Physics Journal, etc.
I hope Minnesotans actively support his efforts.
If you live in Minnesota, contact Rich ( Rvetter at mayo.edu).
Also, please write a letter to your legislative representative
(better yet to all members of the legislature). [E-mail is not
effective.] I think that the only thing that will get their attention
is the anti global warming issue.
Otto
**********************************************
Prof. Otto G. Raabe, Ph.D., CHP
Center for Health & the Environment
University of California
One Shields Avenue
Davis, CA 95616
E-Mail: ograabe at ucdavis.edu
Phone: (530) 752-7754 FAX: (530) 758-6140
***********************************************
------------------------------
Message: 5
Date: Wed, 2 Sep 2009 11:52:50 -0400
From: "Glenn R. Marshall" <GRMarshall at philotechnics.com>
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
To: "Bray, Linda G." <LINDA.G.BRAY at saic.com>, "Johanning, Jeffrey R."
<JEFFREY.R.JOHANNING at saic.com>, "radsafe at radlab.nl"
<radsafe at radlab.nl>
Message-ID:
<597B927DD5BB0840957B5A8D9FBC8FDD07B7A2E041 at TNOR-FPE3.philotechnics.int>
Content-Type: text/plain; charset="us-ascii"
Now I am curious. How is an unlicensed user supposed to know that? 10 CFR 30.18, if an exempt person even knows to red it, only prohibits commercial distribution. It doesn't say they can't give the stuff away; in fact, the person (I paraphrase) is exempt to the extent that such person receives, possesses, uses, transfers, owns, or acquires byproduct material in individual [exempt] quantities. I see nothing in there about tearing off labels and throwing the source away.
Glenn Marshall
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Bray, Linda G.
Sent: Wednesday, September 02, 2009 11:02 AM
To: Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Jeff, they cannot redistribute. That has not changed. They can take it
places and use it, but not sell, uninstall, install, or redistribute.
This does actually make sense, because if they don't have the license,
they don't have the overhead of the tracking, and reports as to where
they were distributed etc. So it makes the process fall apart from that
perspective
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Johanning, Jeffrey R.
Sent: Monday, August 31, 2009 12:39 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
I'm just curious. I had worked on an NRC "E" license a few years ago
and my memory maybe lost or things may have changed. I recall that the
"unlicensed" users of exempt quantities were not allowed to redistribute
them, only tear off the label and throw them away. (which doesn't make a
lot of sense either)??
Just curious of what the current rules are?
Jeffrey R. Johanning
Health Physicist V/RSO
Science Applications International Corp.
858-826-9725
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Geo>K0FF
Sent: Saturday, August 29, 2009 07:36
To: radsafe at radlab.nl
Subject: [ RadSafe ] Seeking exempt quantity sources donation.
Hello.
We are seeking unlicensed (schedule B quantities) exempt quantity sealed
sources, NORM and
"Becquerel Kits" for recycling into educational uses.
Contact me off list for shipping instructions or we can pick up larger
shipments if within driving distance of Oak Ridge, Las Vegas, or St.
Louis
This is an ongoing requirement. The sources will be used to help train
future RP's and in school demonstrations kits as appropriate.
EDUCATORS- contact me offlist if you have a need for one of our loaner
Rad Demo Kits.
George Dowell
New London Nucleonics Lab.
email:
GEOelectronics at netscape.com
TELCO 573-221-3418
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood the RadSafe rules. These can be found at: http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/
------------------------------
Message: 6
Date: Wed, 2 Sep 2009 10:57:19 -0700
From: "Cary Renquist" <cary.renquist at ezag.com>
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
To: "Glenn R. Marshall" <GRMarshall at philotechnics.com>, "Bray, Linda
G." <LINDA.G.BRAY at saic.com>, "Johanning, Jeffrey R."
<JEFFREY.R.JOHANNING at saic.com>, <radsafe at radlab.nl>
Message-ID:
<C3973DA2E426594A8EC6DC90DB0540A004720F7F at ipl-mail.ipl.isotopeproducts.com>
Content-Type: text/plain; charset="iso-8859-1"
"Now I am curious. How is an unlicensed user supposed to know that?"
Because the distributor is required to inform them...
This is what the receiver of the sources will know: (Info required to be affixed to the source or be on a pamphlet/etc that is shipped with the source): [from 10 cfr ? 32.19 (d)]
(1) state that the contents are exempt from NRC or Agreement State licensing requirements;
(2) bear the words "Radioactive Material--Not for Human Use--Introduction Into Foods, Beverages, Cosmetics, Drugs, or Medicinals, or Into Products Manufactured for Commercial Distribution is Prohibited -- Exempt Quantities Should Not be Combined";
and
(3) set forth appropriate additional radiation safety precautions and instructions relating to the handling, use, storage, and disposal of the radioactive material.
Here's the NRC Example Product Brochure:
<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v8/index.html#app_l>
If the receiver doesn't have some sort of specific license, then they are essentially exempt from all NRC/State rules (that includes transferring possession as long as it is not commercial distribution). Just be aware that just like beauty, "commercial distribution" is in the eye of the beholder -- your friendly neighborhood regulator might not agree with what you might think is non-commercial...
FYI: here's the NRC toolkit:
NRC: Exempt Distribution Licensee Toolkit
<http://www.nrc.gov/materials/miau/product-manufac/exempt-toolkit.html>
NRC: Program-Specific Guidance About Exempt Distribution Licenses (NUREG-1556, Volume 8)
<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v8/index.html>
Cary
---
Cary Renquist
cary.renquist at ezag.com
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Glenn R. Marshall
Sent: Wednesday, 02 September 2009 08:53
To: Bray, Linda G.; Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Now I am curious. How is an unlicensed user supposed to know that? 10 CFR 30.18, if an exempt person even knows to red it, only prohibits commercial distribution. It doesn't say they can't give the stuff away; in fact, the person (I paraphrase) is exempt to the extent that such person receives, possesses, uses, transfers, owns, or acquires byproduct material in individual [exempt] quantities. I see nothing in there about tearing off labels and throwing the source away.
Glenn Marshall
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Bray, Linda G.
Sent: Wednesday, September 02, 2009 11:02 AM
To: Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Jeff, they cannot redistribute. That has not changed. They can take it
places and use it, but not sell, uninstall, install, or redistribute.
This does actually make sense, because if they don't have the license,
they don't have the overhead of the tracking, and reports as to where
they were distributed etc. So it makes the process fall apart from that
perspective
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Johanning, Jeffrey R.
Sent: Monday, August 31, 2009 12:39 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
I'm just curious. I had worked on an NRC "E" license a few years ago
and my memory maybe lost or things may have changed. I recall that the
"unlicensed" users of exempt quantities were not allowed to redistribute
them, only tear off the label and throw them away. (which doesn't make a
lot of sense either)??
Just curious of what the current rules are?
Jeffrey R. Johanning
Health Physicist V/RSO
Science Applications International Corp.
858-826-9725
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Geo>K0FF
Sent: Saturday, August 29, 2009 07:36
To: radsafe at radlab.nl
Subject: [ RadSafe ] Seeking exempt quantity sources donation.
Hello.
We are seeking unlicensed (schedule B quantities) exempt quantity sealed
sources, NORM and
"Becquerel Kits" for recycling into educational uses.
Contact me off list for shipping instructions or we can pick up larger
shipments if within driving distance of Oak Ridge, Las Vegas, or St.
Louis
This is an ongoing requirement. The sources will be used to help train
future RP's and in school demonstrations kits as appropriate.
EDUCATORS- contact me offlist if you have a need for one of our loaner
Rad Demo Kits.
George Dowell
New London Nucleonics Lab.
email:
GEOelectronics at netscape.com
TELCO 573-221-3418
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood
the RadSafe rules. These can be found at:
http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings
visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood the RadSafe rules. These can be found at: http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/
_______________________________________________
You are currently subscribed to the RadSafe mailing list
Before posting a message to RadSafe be sure to have read and understood the RadSafe rules. These can be found at: http://radlab.nl/radsafe/radsaferules.html
For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/
------------------------------
Message: 7
Date: Wed, 2 Sep 2009 14:50:37 -0400
From: "Glenn R. Marshall" <GRMarshall at philotechnics.com>
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
To: Cary Renquist <cary.renquist at ezag.com>, "Bray, Linda G."
<LINDA.G.BRAY at saic.com>, "Johanning, Jeffrey R."
<JEFFREY.R.JOHANNING at saic.com>, "radsafe at radlab.nl"
<radsafe at radlab.nl>
Message-ID:
<597B927DD5BB0840957B5A8D9FBC8FDD07B7A2E074 at TNOR-FPE3.philotechnics.int>
Content-Type: text/plain; charset="iso-8859-1"
Cary,
OK, I'll concede the part about the distributor informing them. But the brochure does not legally bind the exempt possessor of the material to do anything. NUREG 1556 V8 applies to persons licensed for exempt distribution in accordance with 10 CFR 32. The exempt person receiving the material is specifically exempt from Part 32 (as stated in 30.18). So if he throws the source away without removing the label or gives it to the kid down the street, it's not a violation of Part 20 (because it's not licensed material), or 30 or 32 (because he's exempt from those parts). Having the manufacturer insert a blurb into the package does not carry the same weight as a regulation - especially when the blurb doesn't even cite the NRC or NUREG 1556, and especially when the recipient is exempt anyway. I'm not necessarily disagreeing with you, I'm just arguing because I like to do that sometimes.
Now I believe the original question had to do with a specific licensee wanting a bunch of exempt sources to distribute them to unlicensed entities such as schools. That requires an exempt distribution license under Part 32.
Glenn
-----Original Message-----
From: Cary Renquist [mailto:cary.renquist at ezag.com]
Sent: Wednesday, September 02, 2009 1:57 PM
To: Glenn R. Marshall; Bray, Linda G.; Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
"Now I am curious. How is an unlicensed user supposed to know that?"
Because the distributor is required to inform them...
This is what the receiver of the sources will know: (Info required to be affixed to the source or be on a pamphlet/etc that is shipped with the source): [from 10 cfr ? 32.19 (d)]
(1) state that the contents are exempt from NRC or Agreement State licensing requirements;
(2) bear the words "Radioactive Material--Not for Human Use--Introduction Into Foods, Beverages, Cosmetics, Drugs, or Medicinals, or Into Products Manufactured for Commercial Distribution is Prohibited -- Exempt Quantities Should Not be Combined";
and
(3) set forth appropriate additional radiation safety precautions and instructions relating to the handling, use, storage, and disposal of the radioactive material.
Here's the NRC Example Product Brochure:
<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v8/index.html#app_l>
If the receiver doesn't have some sort of specific license, then they are essentially exempt from all NRC/State rules (that includes transferring possession as long as it is not commercial distribution). Just be aware that just like beauty, "commercial distribution" is in the eye of the beholder -- your friendly neighborhood regulator might not agree with what you might think is non-commercial...
FYI: here's the NRC toolkit:
NRC: Exempt Distribution Licensee Toolkit
<http://www.nrc.gov/materials/miau/product-manufac/exempt-toolkit.html>
NRC: Program-Specific Guidance About Exempt Distribution Licenses (NUREG-1556, Volume 8)
<http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v8/index.html>
Cary
---
Cary Renquist
cary.renquist at ezag.com
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Glenn R. Marshall
Sent: Wednesday, 02 September 2009 08:53
To: Bray, Linda G.; Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Now I am curious. How is an unlicensed user supposed to know that? 10 CFR 30.18, if an exempt person even knows to red it, only prohibits commercial distribution. It doesn't say they can't give the stuff away; in fact, the person (I paraphrase) is exempt to the extent that such person receives, possesses, uses, transfers, owns, or acquires byproduct material in individual [exempt] quantities. I see nothing in there about tearing off labels and throwing the source away.
Glenn Marshall
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Bray, Linda G.
Sent: Wednesday, September 02, 2009 11:02 AM
To: Johanning, Jeffrey R.; radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Jeff, they cannot redistribute. That has not changed. They can take it
places and use it, but not sell, uninstall, install, or redistribute.
This does actually make sense, because if they don't have the license,
they don't have the overhead of the tracking, and reports as to where
they were distributed etc. So it makes the process fall apart from that
perspective
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Johanning, Jeffrey R.
Sent: Monday, August 31, 2009 12:39 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
I'm just curious. I had worked on an NRC "E" license a few years ago
and my memory maybe lost or things may have changed. I recall that the
"unlicensed" users of exempt quantities were not allowed to redistribute
them, only tear off the label and throw them away. (which doesn't make a
lot of sense either)??
Just curious of what the current rules are?
Jeffrey R. Johanning
Health Physicist V/RSO
Science Applications International Corp.
858-826-9725
-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Geo>K0FF
Sent: Saturday, August 29, 2009 07:36
To: radsafe at radlab.nl
Subject: [ RadSafe ] Seeking exempt quantity sources donation.
Hello.
We are seeking unlicensed (schedule B quantities) exempt quantity sealed
sources, NORM and
"Becquerel Kits" for recycling into educational uses.
Contact me off list for shipping instructions or we can pick up larger
shipments if within driving distance of Oak Ridge, Las Vegas, or St.
Louis
This is an ongoing requirement. The sources will be used to help train
future RP's and in school demonstrations kits as appropriate.
EDUCATORS- contact me offlist if you have a need for one of our loaner
Rad Demo Kits.
George Dowell
New London Nucleonics Lab.
email:
GEOelectronics at netscape.com
TELCO 573-221-3418
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For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/
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For information on how to subscribe or unsubscribe and other settings visit: http://radlab.nl/radsafe/
------------------------------
Message: 8
Date: Wed, 02 Sep 2009 15:15:06 -0400
From: khelm924 at aol.com
Subject: [ RadSafe ] Assistant RSO position
To: radsafe at radlab.nl
Message-ID: <8CBFA18D0FA866A-3CA8-6D7F at webmail-d002.sysops.aol.com>
Content-Type: text/plain; charset="us-ascii"
The University of Louisville has an opening for an Assistant RSO / Senior HP.? The University has 2 Broadscope type A licenses, one covering the main campus, the other covering a Health Sciences Campus ( biomed research and teaching hospital).?
To view the full job description and the submission of an application / or resume, you must go through Human Resources.? Please go to the UofL website at?? www.louisville.edu? , Administration, job.
------------------------------
Message: 9
Date: Wed, 2 Sep 2009 14:51:11 -0500
From: "Geo>K0FF" <GEOelectronics at netscape.com>
Subject: Re: [ RadSafe ] Seeking exempt quantity sources donation.
To: "Glenn R. Marshall" <GRMarshall at philotechnics.com>, "Cary
Renquist" <cary.renquist at ezag.com>, "Bray, Linda G."
<LINDA.G.BRAY at saic.com>, "Johanning, Jeffrey R."
<JEFFREY.R.JOHANNING at saic.com>, <radsafe at radlab.nl>
Message-ID: <9D269782446448038DCEA76A73D884CB at GeorgePC>
Content-Type: text/plain; format=flowed; charset="iso-8859-1";
reply-type=original
Glenn said:
"----- Original Message -----
From: "Glenn R. Marshall" Now I believe the original question had to do with
a specific licensee wanting a bunch of exempt sources to distribute them to
unlicensed entities such as schools. That requires an exempt distribution
license under Part 32.
Glenn "
Concerning schedule B, exempt quantity sources.
Quite correct Glenn. To receive the sources, they must come from a licensed
distributor.
To transfer the sources, they must be transferred by a licensed distributor.
No sort of license is needed to own or use them, but an unlicensed user
cannot combine exempt quantity
sources for the purpose of increasing the radioactivity.
It is true that the NRC rules plainly state that there is no restriction on
ownerships.etc and transferring the material.
It says that in plain language, but the NRC also gives guidance that an
unlicensed person may not "enter the sources into the marketplace", and
further states that is is laughable that anyone would thing the rules
mentioned above would
allow someone to purchase the sources from a licensed place, then give them
away.
That certainly seems contradictory, and no one at the NRC office will defend
either application of the rule. It is not their job to do that.
That is the job of the NRC legal department, and they will not do that for
you for free. It is not their job to do that.
George Dowell
------------------------------
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End of radsafe Digest, Vol 211, Issue 2
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