Re: NRC Licensing of Am-241

[David Scherer <scherer@uiuc.edu>]

At 10:44 AM 10/25/96 -0500, you wrote:
>Wes Van Pelt wrote:
>> In my experience, and in
>> discussions with NRC officials, any NRC licensee who is licensed to
>> possess radioactive material may transfer exempt quantities of it to
>> anyone at all. The catch is that if a NRC specific licensee wants to
>> distribute exempt quantities COMMERCIALLY, he/she must get a specific
>> license which allows COMMERCIAL distribution of exempt quantities.
>
>Wes, This solves my waste disposal problems!  Now I can transfer my waste in 
>individual exempt quantity limits to my local garbage collector. :^) 
>
>If you receive licensed material it is always licensed material, period.  
>Refer to 30.41.  
>
Kent and group:

Section 30.41(b), (3) allows transfer to "any person exempt from the
licensing requirements of the Act and regulations in this part, to the
extent permitted under such exemption."  Section 30.41 (4) allows the same
for Agreement State residents.

Also, Section 30.14 (d) prohibits transfers of exempt concentrations unless
performed under a specific license (Section 32.11).  There is no analogous
rule regarding exempt quantities, though.

So it is permissible to transfer materials to persons exempt by virtue of
30.18 (exempt quantities).  However, this does not give you permission to
transfer this material to your waste hauler without his knowledge or
permission.  (A "transfer" would seem to imply acceptance by the
transferee.)  Also, if two people gave him the max. exempt quantities of the
same nuclide (or you did it twice), he would no longer be exempt, and your
transfer would not comply wth 30.41(b).

Regards,
Dave Scherer
scherer@uiuc.edu