Re: Rad Equipment Exemption

["James G. Barnes" <mail15077@pop.net>]

Dear Joe,

Regarding your questions about exemptions from registration. . . .
> 
> Do other States have a similar exemption?

ANS:  Yes.  California has a similar exemption (CRC Title 17.30125):

"The following devices do not require registration:"

"a)  Electrical equipment that produces radiation incidental to its operation 
for other purposes, but which does not produce radiation in any area accessible 
to individuals such that there is a resonable likelihood that any individual 
will receive a radiation dose to the whole body, head and trunk, gonads, or 
lens of the eye or active blood-forming organs in excess of 0.5 rem in a year."


> What is the intent (ie, is it meant for a specific type of equipment such as 
> CRTs?)?

In California, we are required to petition to remove specific device types from 
registration.  This usually involves a letter requesting exemption, accompanied 
with survey data demonstrating that the dose limits will be met.

California does not seem to restrict it to specific devices; however, one has 
to meet the criteria that the X-rays are produced as a byproduct of the 
equipment's main process or intent.

> Would you interpret this to include electron microscopes (SEMs or TEMs)?  Why
> or why not?

Yes.  They are included.  We have successfully petitioned them from 
registration.

Keep in mind, however, that you would be very wise to have them on some type of 
routine monitoring program for assurance that they continue to meet dose limits 
over time.  One would also want to be especially careful to re-monitor the 
equipment following any maintenance where the system was opened up.


Jim Barnes, CHP
RSO
Rocketdyne Division; Rockwell Aerospace