[ RadSafe ] Seeking exempt quantity sources donation.
Glenn R. Marshall
GRMarshall at philotechnics.com
Wed Sep 2 16:02:24 CDT 2009
Tritium watches and other items must be initially distributed by a person having an exempt distribution license; after that, 10 CFR 30.15 places no restriction on what the individual may do with the item.
The discussion revolves around exempt quantities (differs from exempt items) as described in 10 CFR 30.18. The regulation does not state the item has to be obtained from someone licensed for exempt distribution. It only says that, if all the individual possesses is radioactive material in individual quantities not in excess of Schedule B, he is exempt from all the regulations in Parts 30-34, 36, and 39. And the regulations having to do with waste disposal in Part 20 do not apply, because they only apply to licensed material.
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Bill Rowan
Sent: Wednesday, September 02, 2009 4:24 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Seeking exempt quantity sources donation.
Are you saying that an exempt distribution product, that has been INITIALLY
transferred in accordance with all applicable licenses to an individual;
that said individual is not able to sell, or transfer the item?
There are hundreds of tritium watches and gunsights (exempt distribution
items) on ebay right at this moment that are for sale by individuals and
small jewelry stores.
Is this a violation of the regulations?
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
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