Re: NRC Licensing of Am-241

[rkathren@tricity.wsu.edu (Ron L. Kathren)]

Wes --

Very much appreciate your reply.  Unfortunately, this situation has serious
and expensive implications with respect to human tissue research programs,
and to transshipment of in-vivo counting phantoms and even calibration
sources.  The regulators would do well to address the problem, and create an
exempt quantity or even an exemption for people with internal depositions.
Can you imagine what havoc some by the book enforcement type could wreak
with the existing situation?

Ron



t >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
>
>*********************************************************************
>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
>*********************************************************************
>
>