Re[2]: Uranyl Acetate and Other Source Material

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

     To add to Ruth's comment, another key word is MORE, not less as stated 
     earlier.
     
     Regards,
     Ronald_Goodwin@Health.Ohio.Gov
     


______________________________ Reply Separator _________________________________
Subject: Re: Uranyl Acetate and Other Source Material
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    2/7/96 12:11 PM


     Please take note as to the definition of source material per 10 CFR 
     20.1003:  "Source material means (1) Uranium or thorium or any 
     combination of uranium and thorium in any physical or chemical form; 
     or (2) Ores that contain by weight, one-twentieth of 1 percent (0.05 
     percent), or more, of uranium, throium, or any combination of uranium 
     and thorium.  Source material does not include special nuclear 
     material."
     
     The operative word for the second definition is ORES by weight.
     
     (Standard disclaimer)
     R. Vandegrift
     rvandegr@health.ohio.gov
     
     
______________________________ Reply Separator _________________________________
Subject: Uranyl Acetate and Other Source Material
Author:  radsafe@romulus.ehs.uiuc.edu at Internet 
Date:    2/7/96 9:46 AM
     
     
Hello, Radsafers!
     
In answer to Jack Roque's questions about the above types of material, some 
information is as follows:
     
-It is regulated in 10 CFR 40 as source material, which is defined as 
having less than 0.05%, by weight, of uranium or thorium, or in any 
combination, and does not include special nuclear material, which is also 
regulated in Part 40 along with depleted uranium.
     
-Under these criterion, source material is actually exempted from most 
requirements.  It is, however, a RCRA chemical, and should be managed 
accordingly.  We manage this as a mixed hazard, since there is some amount 
of radioactivity in this material, and as part of ALARA management, we feel 
this is prudent.  We do not require approvals or formal biannual 
inventories, but we did conduct a campus wide inventory a year or so ago, 
to affirm that we do not exceed the % by weight limit.
     
-In the past couple of years, two large broad license universities got into 
difficulty with the NRC because of handling problems.  In one case, the 
waste was managed improperly.  In the other case, a worker alleged to the 
NRC that he/she had received a radiation exposure from source material.
     
This is one of those issues that have very gray foggy edges.  I called the 
NRC and asked their advice on this after the above incidents came to my 
attention, and was told that our management is adequate.  They recommended 
we conduct a survey to see who had it and how much.  We developed a very 
simple form for investigators to use, mailed it to them, and kept the 
returned forms.  We do not log it into our inventory database as we do with 
our licensed/permitted material.
     
That's our 2 cents worth.  Hope it is helpful.  Any questions may be 
directed to me, or to RADSAFE if senders feel it is of general interest.
     
Regards,
     
Kristin
     
All comments herein contained are my own opinions and/or experiences and 
are not necessarily those of my employer or institution.
     
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Kristin Erickson, Radiation Safety Officer
Office of Radiation, Chemical and Biological Safety 
C124 Research Complex-Eng.
Michigan State University
East Lansing, Michigan 48824
Telephone: (517) 355-5008   Fax: (517)353-4871   Email: 10525kfb@msu.edu 
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