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Re[2]: NRC Licensing of Am-241
This argument does not apply since one cannot transfer exempt
quantities for the purpose of disposal.
Eric Darois
daroiel@naesco.com
______________________________ Reply Separator _________________________________
Subject: Re: NRC Licensing of Am-241
Author: radsafe@romulus.ehs.uiuc.edu at Internet
Date: 10/25/96 1:28 PM
In a message dated 96-10-25 14:01:59 EDT, Kent Lambert wrote:
<< If the licensed material becomes an exempt quantity (by decay or by
physically
splitting the source) then the person that possesses the exempt quantity
material
no longer needs a license. Then, the material is no longer licensed
material.
As a result, part 20 does not apply. And I can do anything I want to with
it.
Ta DA, my waste disposal problems are over.
Somehow, I don't think that's how it works. >>
You're right. It doesn't work like that. One can pretty much rely on the
fact that once an item is licensed, it remains licensed through legal
disposal. For example, Tc-99m used in nuclear medicine procedures becomes an
"exempt quantity" pretty quickly, but the medical users are NOT exempt from
legally disposing of the material (via decay in storage), and maintaining
records of that disposal.
Barbara L. Hamrick
Los Angeles County - Radiation Management
BLHamrick@aol.com