Re: Exempt quantities

[William V Lipton <liptonw@dteenergy.com>]

The NRC interprets this otherwise.  See HPPOS-190:  "... Sections 20.301, 30.14,
30.18, and 40.13(a) of CFR Title 10 do not authorize waste disposal by transfer of
exempt quantities of byproduct and/or source materials to persons who do not hold a
specific NRC license authorizing them to receive it.  The health physics position
was written in the context of 10 CFR 20.301, but it also applies to "new" 10 CFR
20.2001..."

The opinions expressed are strictly mine. (In this case the HPPOS is an official
opinion of the NRC).
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

Wes Van Pelt wrote:

> Bill,
>
> No, not so.
>
> If a licensee receives one or more license exempt quantities, then he/she may
> possess, use, transfer, etc. those exempt quantities separate from the
> requirements imposed by the specific license.
>
> Simply by having a specific license one does not give up the right to possess
> license exempt quantities under the same conditions as persons with no license.
>
> Wes
> --
> Wesley R. Van Pelt, Ph.D., CIH, CHP            KF2LG
> President, Van Pelt Associates
> Radiation Safety and Environmental Radioactivity
> mailto:vanpeltw@idt.net    http://idt.net/~vanpeltw/
>
> William V Lipton wrote:
>
> > If you read 10 CFR 30.18, you'll see that it only applies to  exempt persons,
> > i.e. a person who does not have a license and who legally handles only
> > individual quantities less than Schedule B.  However, if you have a license,
> > then ALL of your RAM is governed by the conditions of this license, including
> > restrictions on the transfer, i.e., disposal of this material.
> >
> > The opinions expressed are strictly mine.
> > It's not about dose, it's about trust.
> >
> > Bill Lipton
> > liptonw@dteenergy.com
>
> ************************************************************************
> The RADSAFE Frequently Asked Questions list, archives and subscription
> information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html

************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html