Re[2]: NRC REG. Exempting Check Sources

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     Okay,
     I tried to send this via specific reply but the internet kept getting 
     in my way.
     
     10CFR30.15(a)(9)(i) which refers user to 10CFR30.71 Schedule B.  That 
     can be tied to 10CFR30.18 for complete coverage.  
     
     If I am wrong, its a good thing my employer only uses me for generic 
     work around here.
     
     R.R.Goodwin
     Ronald_Goodwin@health.ohio.gov
     


______________________________ Reply Separator _________________________________
Subject: Re: NRC REG.  Exempting Check Sources
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    1/25/96 8:02 AM


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