RE: Re[3]: NRC Licensing of Am-241

["Spell, Bill" <bills@deq.state.la.us>]

Please bear in mind that HP position papers do not regulatons make.  My 
point is that because it is a well-reasoned, scientifically-correct 
document, easy to understand, etc., it is not a regulation, and it may be in 
direct conflict with those regulations which apply to you and your 
institution.


Bill Spell
bills@deq.state.la.us

Solely my opinion
 ----------
From: radsafe
To: Multiple recipients of list
Subject: Re[3]: NRC Licensing of Am-241
Date: Friday, October 25, 1996 10:01AM

     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