Re: Exempt quantities

[Debby Steva <dps3c@virginia.edu>]

I think it might be useful to take a look at NMSS Licensee Newsletter, NUREG/BR-0117
Nol 99-1 March -April 99 - NRC Technical Policy on Specific Licensee possession of
exempt quantities pursuant to 10CFR30.18 -  it specifically states "the specific
licenssee can continue to receive and treat the material distributed by an exempt
distribution licensee, as a person exempt from licensing, provided the material is
received and maintained as exempt material at all times, and the person's specific
license does not contain a condition to the contrary."

D. Steva

William V Lipton wrote:

> 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
> >
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