Re: NRC REG. Exempting Check Sources

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

Yes, but....(And there are differing opinions on this one, so add all
suitable disclaimers):

The public school (recipient) would have to want the radioactive
material as a user.  If the school was just going to throw it away
for you, it would be a violation.  However, the recipient could later
decided that they didn't want the material and threw it away after
never using it.  It all comes down to intent, of course, which makes
things tricky.

Wes

> Date:          Thu, 1 Feb 96 15:11:26 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          "Dale E. Boyce" <dale@radpro.uchicago.edu>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: NRC REG.  Exempting Check Sources

> A twist to what Wes says about exempt quantities is that they
> must be distributed under an "E" license if it is "commercial"
> distribution.  A licensee could give an exempt quantity to
> someone without an "E" license.  However, NRC guidance prohibits
> declaring a quantity exempt for the purposes of disposal.  So a
> licensee could give an exempt quantity to a public school, but
> not the local landfill. ;)
>
> Some agreements state(s) have modified the language of their
> regulations to restrict what licensees can treat as exempt.
>
> Dale Boyce
> dale@radpro.uchicago.edu
>
*********************************************************************
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
*********************************************************************