Re: Exempt quantities

[Wes Van Pelt <vanpeltw@idt.net>]

Radsafers,
Debby and William and I are all correct in our statements below. There is no conflict
among our statements.
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/


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..."
> >
> > 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
> > >


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