Re: Exempt quantities

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

NOT AT ALL!

Read the rest of the NMSS Newsletter article that was quoted out of context:

"Although the provisions of 10 CFR 30.18 exempt any person from the requirements for a
license and from the regulations in 10CFR Parts 30-34 and 39 for exempt quantities, other
parts of the Commission's regulations may be applicable to the activities of specific
licensees involving the use of exempt quantities (e.g., certain requirements found in Part
20). For example, because
10 CFR 30.18 is silent regarding specific licensee activities governed by Part 20
regulations, Part 20 is applicable. And, because Part 20 is applicable in determining both
public and occupational doses from unlicensed material as well as licensed materials,
exempt materials must be considered when a licensee calculates such doses.

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. "

Clearly, a licensee who possesses "exempt" sources has requirements for these sources
beyond those imposed on a non-licensee.

The opinions expressed are strictly mine.
It's not about dose it's about trust.

Bill Lipton
liptonw@dteenergy.com

Wes Van Pelt wrote:

> 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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