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Exempt Quantities
Attached is an NRC Health Physics Position Paper that discusses allowances
for non-commercial, non-waste distribution to non-licensees of exempt
quantities/concentrations.
+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
> Transfer of Exempt Quantities of By-product Material from a
> Nuclear Power P lant
>
> HPPOS-189 PDR-9111210298
>
> Title: Transfer of Exempt Quantities of By-product
> Material from a Nuclear Power Plant
>
> See the memorandum from L. J. Cunningham to R. R. Bellamy
> (and others) dated July 15, 1987. Enclosed with this
> memorandum are two others: the first from L. J. Cunningham
> to R. L. Fonner dated May 7, 1987; and the second from R.
> L. Fonner to L. J. Cunningham dated June 30, 1987. These
> memos state that exempt quantities of byproduct material,
> pursuant to 10 CFR 30.18, can be transferred from a nuclear
> power plant to a non-licensed laboratory provided: the
> transfer must not be for waste disposal, the transfer must
> not be for commercial distribution, and the material must
> not contain special nuclear or byproduct material other
> than that included in 10 CFR 30.71, Schedule B. HPPOS-131
> and HPPOS-203 contain related topics.
>
> The transfer of exempt quantities of byproduct material
> from a nuclear power plant to a non-licensee is
> permissible, provided all of the following general
> conditions are met.
>
> 1. The transfer meets all of the applicable
> requirements of 10 CFR Parts 20-71.
>
> 2. The transfer meets all applicable radioactive
> material transportation requirements of the U.S. Department
> of Transportation (49 CFR 100-178) and the U.S. Postal
> Service (39 CFR 124).
>
> 3. The transfer does not violate any applicable state
> regulations.
>
> In more specific terms, the transfer, pursuant to 10 CFR
> 30.18, must meet all of the following conditions:
>
> 1. The transfer must not be for purposes of waste
> disposal.
>
> 2. The transfer must not be for purposes of commercial
> distribution, except in accordance with a license issued
> under 10 CFR 32.18 stating that the byproduct material may
> be transferred to persons exempt under 10 CFR 30.18 or
> equivalent Agreement State regulations [10 CFR 30.18 (c)
> and (d)].
>
> 3. The material transferred must not contain special
> nuclear material or byproduct material other than that
> included in 10 CFR 30.71 Schedule B. The reactor licensee
> transferring exempt quantities of byproduct material must
> provide reasonable assurance that the material transferred
> does not contain radionuclides not included in 10 CFR 30.71
> Schedule B.
>
> Regulatory references: 10 CFR 30.18, 10 CFR 30.71
>
> Subject codes: 3.5, 11.1, 12.10
>
> Applicability: Reactor
>
Stu Torf
torfsm@nu.com