re[2]: Cs137/Ba137m generators

[Harry Newman <hresources@NEXTEP.CC>]

Barbara-

Thanks for setting me strait.  On looking at the original transmittal from Walt, it appears he works at a university and therefore probably has a license.  I agree with your interpretation.  Licensees should comply with their license and 10 CFR 20 in dealing with the materials.



Harry J. Newman

NEXTEP Environmental

hnewman@nextep.cc



  >>  In a message dated 11/14/2001

  >>   10:12:53 AM Pacific Standard

  >>   Time, 

  >>  hresources@NEXTEP.CC writes:





  >>  > I always have interpreted and

  >>   exempt quantity as appling to a

  >>   device.  

  >>  > Remember, the MANUFACTURER of

  >>   the device is licensed to

  >>   distribute the 

  >>  > device as exempt.  Therefore,

  >>   the device itself has been

  >>   through the 

  >>  > regulatory grist mill and has

  >>   been deemed acceptable for

  >>   manufacture and 

  >>  > for general distribution.

  >>  > 

  >>  > 



  >>  I believe, however, that the NRC

  >>   interpretation is that "persons"

  >>   are exempt, 

  >>  not devices or sources, thus if

  >>   you have a specific license, you

  >>   cannot be a 

  >>  person exempt, even for the

  >>   purposes of receiving a source

  >>   that could be 

  >>  distributed to persons who are

  >>   exempt.



  >>  Was that as clear as mud?  I

  >>   thought so.



  >>  When in doubt, it doesn't hurt to

  >>   check with your regulating

  >>   agency.



  >>  Thank you,

  >>  Barbara L. Hamrick

  >>  BLHamrick@aol.com

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