Re: Re[2]: NRC Licensing of Am-241

[BLHamrick@aol.com]

In a message dated 96-10-25 09:29:24 EDT, Bill Spell wrote:

<< Not quite, Ron.  The manufacturer has a specific license to manufacture
and 
 distribute the devices to persons generally licensed.  And, single smoke 
 detectors may be disposed of via trash to a sanitary landfill.  A dealer, 
 manufacturer, etc., cannot dispose of quantities of these at one time in 
 this manner, however.  At least, this was it the last time I heard.  >>

Not quite there yet.  The NRC licenses persons to manufacture and distribute
products for exempt distribution.  (They also retain control over
"E-licensees" in Agreement States.)  The persons who receive these items (in
this case smoke detectors) are exempt from licensing and from the regulations
parts 20 and 30 (and some others - I don't have my regs with me).  It is 10
CFR 30.20 (I'm pretty sure) which exempts person from these requirements if
they possess, receive, etc. (not manufacture, initially distribute, etc.)
smoke detectors containing Am-241 (as long as those devices were originally
manufactured and distributed under an E-license).

There is a memo which was recently (a few months ago) distributed to the
Agreement States (and, presumably NRC offices) which reiterated the NRC's
position that persons exempt from licensing CAN dispose of smoke detectors,
even in bulk, without regard to their radioactivity.  This does NOT allow the
persons licensed to manufacture, distribute, etc. to dispose of these
detectors in that way.

Finally, with regard to the non-commercial transfer of exempt items by
licensees.  I wish I had that memo in front of me, because the issue is
addressed, but I do recall that at least one restriction is that transfers of
exempt items cannot be made for the purpose of disposal.  That is, one can't
divide up a non-exempt quantity of material into "exempt quantities" then
transfer them to unlicensed persons for the purpose of disposal.

I hope if I've gotten this all wrong, someone will set me straight.

Barbara L. Hamrick
Los Angeles County - Radiation Management
(We're a contract county, performing inspections for an Agreement State.)
(Lot's of people ask.)  
BLHamrick@aol.com

P.S. I do have copies of the aforementioned memo, if the requests aren't
overwhelming, I can fax a copy of the memo.  (I don't have a computerized
version.)