Re[2]: A Technical (Licensing) Question!

[steve.rima@doegjpo.com (Steven Rima)]

     Bill et al,
     
     Here's a little more information on this subject that complicates it. 
     The facility in question (lab) is on a DOE site and has never been 
     subject to either NRC or State licensing or regulation. Yes, there is 
     some scant evidence that transuranics have been analyzed there in the 
     past. However, the waste stream is (hopefully) destined for a mill 
     tailings disposal cell that, when closed, will come under an NRC 
     license. The NRC is telling us that *we* should determine whether the 
     Pu is licensable or not, and whether it can go to the cell, and tell 
     them what our answer is. I've looked at 10 CFR 40, 70, etc..... and 
     found no good answer.
     
     A strict interpretation of 10 CFR 70 would lead one to believe that 
     one atom of Pu is subject to licensing, but as others have pointed 
     out, that's absurd. It's such fun to deal with regulatory agencies 
     sometimes! :-)
     
     Steve
     
     Steven D. Rima, CHP, CSP
     Radiation Safety Officer
     MACTEC, Inc.
     970-248-6787
     fax 248-6725
     cell 260-3848
     steven.rima@doegjpo.com
     or
     sdrima@mactec.com


______________________________ Reply Separator _________________________________
Subject: Re: A Technical (Licensing) Question!
Author:  William V Lipton <liptonw@dteenergy.com> at Internet
Date:    8/11/00 6:06 AM


I'm not aware of any exemptions for SNM.  The only relaxation of the 
regulations is provisions for a general license for calibration or reference 
sources, in 10 CFR 70.19.
     
A few questions that you should be asking?
     
(1)What is the history of the facility you're decommissioning?  Did they use 
SNM?
(2) If they did, then how did they terminate their license?
     
The opinions expressed are strictly mine. 
It's not about dose, it's about trust.
     
Bill Lipton
liptonw@dteenergy.com
     
Steven Rima wrote:
     
>      RADSAFERs,
>
>      I actually have a technical question that I am hoping someone can 
>      assist me with. I've been looking through 10 CFRs, becoming more
>      frustrated the more I look (Imagine that!) Here's the question: What 
>      quantity of SNM (Pu 239/240) requires a license for possession, use, 
>      etc.? A regulatory citation would be great.
>
>      Here's a little background information: We have analyzed samples from 
>      the ducting in a radiochemistry laboratory that is slated for
>      demolition. If we count the samples long enough, a few show extremely 
>      small trace amounts of Pu 239/240. I'm not completely convinced that
>      it's really there, but I can't positively rule it out either. It seems 
>      to me that a concentration and/or quantity below which licensing is
>      not required would be in the regulations somewhere, but I've not found 
>      it. If I find a few atoms of SNM in an entire building, is a license
>      needed?
>
>      Thanks in advance,
>
>      Steve
>
>      Steven D. Rima, CHP, CSP
>      Radiation Safety Officer
>      MACTEC, Inc.
>      970-248-6787
>      fax 248-6725
>      cell 260-3848
>      steven.rima@doegjpo.com
>      or
>      sdrima@mactec.com
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