Re: A Technical (Licensing) Question!

[Rodney Bauman <rodney_bauman@wssrap-host.wssrap.com>]

Steven:

OK, the problem is a little different than my previous interpretation.  You've
got DOE radioactive material and you're trying to determine the NRC-license
applicability.  You've got no specific exemption for the plutonium.  I've
experienced the same problem with "byproduct material" as defined by 10CFR40.4. 
There are no exempt licensing quantities for this type of "byproduct material" 
(i.e., AEA 11(e)2 material).  The NRC prefers not to deal with it.  Every time
we question them on the "licensability" of such material, they tells us to apply
the same exemptions applicable to 10CFR40.4 "source material."  The NRC has
stated that they were revising 10CFR40 in order to provide specific exemptions
for 11(e)2 byproduct material.  Whether or not this is actually true, I don't
know.

It looks like you've got the same problem with SNM.  I can't give you a good
quick answer - I can only share your grief.  Sorry.  However, I would be
interested in knowing how you resolve this issue.

Rodney Bauman, CHP, RRPT
rodney_bauman@wssrap-host.wssra.com


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