Re: NRC Licensing of Am-241

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

Ron,

I really have no interest in taking an official, regulatory, stand on 
that.  Personally, however, I would say that there was no transfer 
or receipt - "it just showed up" (NOTE: don't try using this line 
with regards to your industrial radiography sources or a small 
puppy).  

This is one of those grey areas that most regulators are clever 
enough to stay out of -- since the literal rule may require an absurd 
implementation (you would have to move your bioassay records to 
reside with your inventory records, for example).  

Wes

> Date sent:      Thu, 24 Oct 96 17:58:26 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           rkathren@tricity.wsu.edu (Ron L. Kathren)
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Re: NRC Licensing of Am-241

> Wes --
> 
> Interesting.  What about people who have a deposition of a few nanocuries as
> a result of occupational exposure?  Do they need a license?
> 
> Ron
> 
> >
> >The answer is: Yep.  Any amount of Am-241 must be licensed.  However, 
> >you'll also note that there are (admittedly small) effluent release 
> >limits in 10 CFR 20 App B.  So you don't have to have a license if 
> >you find some trace levels in your air and/or water.  But you can't 
> >transfer or receive it without the license.
> >
> >Wes

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Wesley M. Dunn, CHP                        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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