Re: Delivery of radioactive sources

["Don Jordan" <ramservices@lsol.net>]

The short answer to your question is that, yes, you should certainly request
a copy of the recipient's license before shipping the source and include a
copy with the export paperwork.  You should also try to pre-clear the item
through U.S. Customs via a freight forwarder & a customs broker.

The longer answer is more complex.  The applicable regulation is 10 CFR
110.27, paragraph (a)(3), which grants a general license to import source,
byproduct and special nuclear material, under certain restrictions,  to
persons with a specific license issued by the U.S. NRC or an "Agreement
State", to possess the material in question.  Your source is most probably
"byproduct material" and would be covered by this regulation.  Including a
copy of the recipient's specific license seems (to me) necessary to invoke
the general license granted by 10 CFR 110.27.

However, certain strange features of U.S. regulation may kick in.  If your
source contains naturally occurring or accelerator produced radioactive
material, e.g. Co-57 or Ra-226, and the recipient is located in an NRC
jurisdiction, then the recipient would not have an NRC license for this
material because the NRC does not regulate such materials and the State may
not regulate the material as well (e.g., Missouri).  So it matters very much
as to exactly what you wish to ship and where you want to ship it.

You may consult the U.S. NRC regulations at the web site
www.gpo.gov/nara and select "Code of Federal Regulations".  The select the
Search or Browse option and choose Title 10, Energy as the volume to look
at.


Don Jordan
RAM Services, Inc.
ramservices@lsol.net
Tel. +1.920-793-2259
Fax +1.920-793-5886

2306 West River Street
Two Rivers, WI  54241

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