Re: NRC REG. Exempting Check Sources

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Some clarifications seem to be in order:

For sealed sources:

The recipient of an exempt source is exempt from 10CFR (or
equivalent).  That means waste, handling, storage, ect... can be done
any old way you wish (as far as being radioactive: this doesn't
exempt you from anybody else's regulations, such as hazardous waste
disposal).

A licensee who uses an exempt source is NOT required to handle that
exempt source in accordance with the license, since the license does
NOT authorize that exempt source in any way, shape or form.  If
anyone tells you differently, politely ask what "exempt from Parts 30-
34, 36 and 39 of this chapter" means [10CFR30.18(a)].  And, if they
say you still have to follow Part 20, ask them what 10CFR20.1002
means (which specifies that Part 20 only applies to licensed
material).

However, the exempt source MUST be initially distributed under an NRC
"E" license.  If the distributer does not have an "E" license, then
the source must be distributed as licensed material.

NOTE: "exempt" is NOT the same as "generally licensed", for which
certain regulatory requirements are imposed upon the recipient.

Wes

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Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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