Re[2]: NRC Licensing of Am-241

["Eric L. Darois" <daroiel@naesco.com>]

     Wes
     
     I believe that intakes (accidental or otherwise) are not considered a 
     transfer of radioactive material governed by part 30.  As you know, 
     exposure to intakes is per part20 or by specific license conditions.  
     In theory this is ananalyzed exposure pathway, so a specific license 
     is not required for individuals with uptakes.  ???
     
     Eric


______________________________ Reply Separator _________________________________
Subject: Re: NRC Licensing of Am-241
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    10/24/96 6:03 PM


Eric --
     
Please see my memo to Wes.  As far as I am aware, the now famous victim of 
the Hanford americium accident did not have a license.  And, how was he 
buried without a license.  I believe that the definition of TRU waste would 
apply.
     
Ron
     
>     This appears to be a confusing issue but not just for Am-241. 
>     
>     It is my understanding that the quantites listed in 10CFR30.71 are 
>     used to establish exempt quantities mainly for source distributors but 
>     ONLY if they have an exempt distribution license.  For example, a 
>     licensee cannot simply declare a 5 uCi Cs-137 source "exempt" unless 
>     it is distributed under an E distribution license.  The same is true 
>     for the inverse: a licensee cannot send a non-licensee 5 uCi of Cs-137 
>     unless it is a source distributed as exempt.  Otherwise, this would be 
>     a handy way of reducing one's stockpile of radioactive material; one 
>     exempt quantity at a time.
>     
>     Therefore, the exempt quantities listed in 30.71 applies as a guide to 
>     someone licensed to distribute exempt sources and also applies to 
>     individuals non-licensed to recieve sources distributed as "EXEMPT".  
>     The licensed conditions may impose additional restrictions.
>     
>     For Am-241, there is no pre-determined exempt amount except as the 
>     original message noted in 30.15.  Therefore, this isotope is not 
>     distributed in any amount as an exempt quantity. 
>     
>     Again, this is how I understand the process, are there other 
>     interpretations ???
>     
>     Eric Darois, CHP
>     daroiel@naesco.com
>
>
>______________________________ Reply Separator 
_________________________________
>Subject: NRC Licensing of Am-241
>Author:  radsafe@romulus.ehs.uiuc.edu at Internet 
>Date:    10/24/96 7:39 AM
>
>
>Can anyone tell me why Americium-241 is not listed in 10CFR30.71, Schedule B? 
>     
>I know that it is mentioned in 30.15 at 0.05 microcuries for sources in 
>ionizing radiation measureing instruments.  
>     
>Since it's not listed, does this mean that "ANY" amount of Am-241 must be 
>licensed by the NRC?
>     
>**************************** /^\   /^\ ********************************* 
>Tad  Blanchard              /__ \ /___\    NASA-Goddard Space Flt Ctr 
>Nat'l Health Svc, Inc            O             Greenbelt, Maryland     
>Sr Health Physics Tech          / \            Phone: 301-286-9157     
>                               /___\           Fax:   301-286-1618       
>                  Tad.M.Blanchard.1@GSFC.NASA.gov                   
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