Re[3]: NRC Licensing of Am-241

["ERIC GOLDIN" <goldinem@songs.sce.com>]

     Regarding the transfer of small quantities of licensed 
     radioactive material, you can find NRC regulatory guidance to 
     reinforce (or kill) your position in NUREG/CR-5569, "Health 
     Physics Positions Data Base."  (There is even a handy DOS-based 
     computer code that will let you search by regulation, subject, 
     etc.)  In that database, you'll find HP Position #189 says you 
     may transfer exempt quantities of rad mat'l to non-licensed labs 
     for analysis, Position #190 says you can NOT transfer exempt 
     quantities for the purpose of disposal, and Position #131 
     discusses the overall issue of exempt quantities and transfer of 
     same.  Handy stuff when pressed to design release programs, etc.  
     By the way, Eric Darois is correct regarding disposal - the NRC 
     position (see HPP #221) is quite clear that, for disposal, 
     anything detectable moves the material into the radwaste 
     category.  And the detection requirements are the state of the 
     art "environmental" levels in standard technical specifications 
     or IE Circular 81-07-style levels for surface contamination.
     
     Eric Goldin
     Southern California Edison
     goldinem@songs.sce.com