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Re: Exempt quantities



Bill Lipton wrote:

>YOU ARE WRONG!...

>"...It is an OELD [Office of the Executive Legal Director] opinions that

>radioactive material held under license can only be disposed of pursuant to 10

>CFR Part 20, even when the quantity disposed is less than that listed in 10

>CFR 30.71, Schedule B...."

The key here is "held under a license". Exempt sources by definition do not require a license. Persons who acquire them are exempt from licensure. The disposal requirements in 10 CFR 20 apply only to licensees.

New York's 12 NYCRR 38 has a similar provision. I don't know about other states, but I strongly suspect that their regs also conform.

************************************************************************
Clayton Bradt, CHP <raldrich@nysnet.net>        phone: 518/457-1202
Assoc. Radiophysicist                                             fax:      518/485-7406
NYS Dept. of Labor
Radiological Health Unit
Blg.12, Rm 169
State Office Campus
Albany, NY 12240
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