RE: Cs137/Ba137m generators

["Perrero, Daren" <Perrero@IDNS.STATE.IL.US>]

I have heard both versions of this discussion boiled down to 'once exempt

always exempt' and 'there are no "exceptions" for specifically licensed

persons'.  I'll admit as a regulator, its never been made very clear to me

in a consistent fashion.



The most recent information from the NRC (NUREG 1556 series, Vol. 8)

"Licensing Guidance for Exempt Distribution" includes an example product

brochure in Appendix L which points out that materials distributed pursuant

to an "E-distribution license" are still subject to 10 CFR 20 for those

facilities that are specifically licensed.  Similar NUREG guidance for

licensees of broadscope (vol 11) point out that possession of generally

licensed material must be considered as specifically licensed material and

tracked as such.



It would be great if the NRC could point to a single reference to make this

more clear to those of us in the 'real world'.  In that aspect I would

qualify Ms. Hamrick's statement below of 'call your local regulator' as

instead a recommendation of 'get it in writing from your local regulator'!



The thoughts expressed are mine, mine, all mine!

I'm with the government, I'm here to help........

Daren Perrero, Health Physicist

perrero@idns.state.il.us





-----Original Message-----

From: BLHamrick@AOL.COM [mailto:BLHamrick@AOL.COM]

Sent: Friday, November 16, 2001 10:34 AM

To: wesvanpelt@ATT.NET; radsafe@list.vanderbilt.edu

Subject: RE: Cs137/Ba137m generators





In a message dated Fri, 16 Nov 2001  9:06:29 AM Eastern Standard Time, "Wes

Van Pelt" <wesvanpelt@ATT.NET> writes:



<<Barbara and all,

Not so.  Even if a person or institution has a specific radioactive material

license, he/she/it

can also take advantage of receiving using and transferring exempt and

generally licensed materials. The only cross over is that the specific

licensee must sum any radiation dose to personnel from both licensed and

exempt

materials. Also, there is no limit on the number of exempt quantities that a

person may possess.>>



In a June 12, 1996 letter from Dr. Carl Paperiello (then Director for NRC's

Office of NMSS), he states with respect to the exemptions in Part 30, "it is

signficant to recognize that the rule language exempts 'persons' rather than

products...the waste disposal requirements specified in Part 20 do not

affect the NON-LICENSED individuals who possess products pursuant to 10 CFR

30.14 through 30.20." (CAPS added for emphasis).  They do affect specific

licensees.



Barbara L. Hamrick

BLHamrick@aol.com

 



I originally wrote:



<< 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 >>

************************************************************************

You are currently subscribed to the Radsafe mailing list. To unsubscribe,

send an e-mail to Majordomo@list.vanderbilt.edu  Put the text "unsubscribe

radsafe" (no quote marks) in the body of the e-mail, with no subject line.