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Re: Exempt quantities
You are on the verge of quoting out of context. If you read that newsletter carefully,
it states:
"In summary, a non-licensee possessing radioactive material exempt under 10 CFR 30.18 has
no regulatory obligations. However, a licensee must take exempt sources into account
under its radiation safety program based on the licensee's
determination of total dose to workers and members of the public pursuant to Part 20. "
Although the NRC doesn't seem to express itself very well on this. the intent is clear.
To me, this implies that the provisions of 10CFR20.2001 apply to "exempt" sources
possessed by a licensee. An uncontrolled release to the public, such as in normal trash,
would definitly impact dose to the public.
As a comparison, consider the exemptions for "self-luminous products ..." in 10 CFR
30.19, and "gas and aerosol detectors..." (i.e., smoke detectors) in 10 CFR 30.20. These
exemptions specifically exempt the user from the requirements of 10 CFR 20 (based on a
safety analysis), while the provisions for "exempt quantities" in 10 CFR 30.18 do NOT
exempt the user from the provisions of 10 CFR 20.
Allow me one "flame." I find it curious that many of those who look for loopholes in the
regulations, so they can throw sources in clean trash or carry radioactive material in
their luggage on airplanes , are the same ones who enjoy playing the victim and can't
understand why the public doesn't accept nuclear technology. "We have met the enemy and
he is us." (Pogo)
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
Debby Steva wrote:
> 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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> > > information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
> >
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information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html