[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
The following question was submitted to the NRC during the
comment period on the new Part 20. Their
The following question was submitted to the NRC during the comment period on the new Part 20. Their answer
may shed some light on the discussion regarding storage and control of exempt quantities.
QUESTION 129: 10 CFR 20.1801 and 20.1802 do not specify quantities of radioactive material below which
unauthorized access to, unauthorized removal from, or the maintenance of constant surveillance over, are not
required in controlled areas. Will these requirements be imposed (a) on all quantities of licensed material, however
small and (b) on quantities that are exempt from labeling by 10 CFR 20.1905(a) and (b)?
ANSWER: (a) No. The requirements of 10 CFR 20.1801 and 20.1802 are not new; they are essentially the same
as the requirements of 10 CFR 20.207(a) and 20.207(b) except that the revised Part 20 requirements apply to
controlled areas as well as unrestricted areas. NRC will continue to enforce these requirements as it has in the
past. (b) No. (References: 10 CFR 20.1801, 20.1802, 20.1905)
Donald E. Parry
Health Physicist
Michigan Department of Public Health
(517) 335-8220
>>> <LIPTONW@detroitedison.com> 01/25/96 10:04am >>>
--Boundary-1417374-0-0
10 CFR 20.1001(b) states that: "It is the purpose of the regulations in this part to control the receipt, possession,
use, transfer, and disposal of licensed material by any licensee in such a manner that the total dose to an
individual (including doses resulting from licensed and unlicensed radioactive material and from radiation sources
other than background radiation) does not exceed the standards for protection against radiation..." I interpret this
to mean that if you are NOT a licensee, you can possess "exempt quantities" without any NRC regulation, but that,
if you ARE a licensee, you are responsbile for all radioactive material in your control. Also, you must keep in mind
that if radioactive material leaves your property, the transportation regulations of 49 CFR apply, so simply throwing
"exempt" sources in the trash would be a DOT violation, in addition to a potential NRC violation.
--Boundary-1417374-0-0
X-Orcl-Content-Type: message/rfc822
Received: 25 Jan 1996 09:01:49 Sent: 25 Jan 1996 08:00:26
From:"root@romulus.ehs.uiuc.edu" <root@romulus.ehs.uiuc.edu>
To: Multiple,recipients,of,list,radsafe@romulus.ehs.uiuc.edu
Subject: Re: NRC REG. Exempting Check Sources
Reply-to: radsafe@romulus.ehs.uiuc.edu
X-Orcl-Application: Errors-To: melissa@romulus.ehs.uiuc.edu
X-Orcl-Application: Originator: radsafe@romulus.ehs.uiuc.edu
X-Orcl-Application: Sender: radsafe@romulus.ehs.uiuc.edu
X-Orcl-Application: Precedence: bulk
X-Orcl-Application: X-Listserver-Version: 6.0 -- UNIX ListServer by Anastasios Kotsikonas
X-Orcl-Application: X-Comment: Radiation Safety Distribution List
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
*********************************************************************
--Boundary-1417374-0-0--