Re: NRC Licensing of Am-241

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Ron,

I can understand your concern.  I see two issues: 

(1) Do not most of these facilities already have a license?  If so, 
then the lack of an exemption should have little or no effect on their 
operations; and

(2) Like most critters, regulators are typically spending time 
putting out yesterday's fires, not looking for new problems to solve. 
Our licensees want their authorizations now, not after we've gone and 
solved somebody else's unworthy problem.  Only the NRC possesses a 
dedicated Research division looking for solutions in need of 
regulations.  The States rarely have the time or resources to address 
such cases unless a serious health and safety issue emerges (such 
as Industrial Radiography in the 80's, and xrfs in the 60's).  

If this is indeed a serious problem (or, as has been suggested, has it 
already been addressed?), I would strongly recommend that the users 
present the problem, the solution, and the rationale.  This can be 
handled through a "request for information", which could lead to a 
Position Paper (probably the better course) or Petition for a 
Rulemaking.  

The HPS, for example, should strongly consider being more pro-active 
in process of "fixing" regulatory problems.  The users have a great 
amount of expertise, skill and knowledge that they rarely provide to 
the regulatory process.

This is obviously a personnal opinion.

Wes

> Date sent:      Fri, 25 Oct 96 11:00:39 -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 --
> 
> 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
> >> 

*********************************************************************
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
*********************************************************************