Re[4]: NRC Licensing of Am-241

["Eric L. Darois" <daroiel@naesco.com>]

     Thank you Eric (Eric Goldin) for forcing me to re-read the HP 
     positions.  As was already pointed out these are not regulations but 
     to take a different direction may cause considerable consternation at 
     some risk, and plenty of time.  I will paraphrase my re-reading..
     
     Exempt quantities can be transferred to non-licensees provided it is 
     not for waste disposal or for commercial distribution or if the 
     reciepient intends to transfer for the same reason.  The NRC 
     interprets commercial distribution as any means to introduce the 
     material into the marketplace (regardless of the transfer of $$$). 
     
     This seems to mean that I can transfer exempt quantities to 
     fission/activation products to a university for research purposes.  Or 
     take for instance a 1.2 microcurie (5 yrs ago) Co-60 source, this can 
     also be donated to an institution provided it is not intended for 
     commercial distribution or disposal.
     
     I recognize that allowing individuals to exit the RCA with exempt 
     quantities may be considered a form of waste disposal, therefore, not 
     allowed.
     
     Another interpretation is that sources requiring inventory 
     (non-exempt) thru licensed conditions may become exempt by decay and 
     therefore are not required to be included in the inventory once below 
     the exempt quantity limit.
     
     This has been a valuable discussion, thank-you all for participating.
     
     Eric Darois
     Seabrook Station
     daroiel@naesco.com


______________________________ Reply Separator _________________________________
Subject: Re[3]: NRC Licensing of Am-241
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    10/25/96 10:01 AM


     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