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Re: NRC Licensing of Am-241




>>
>>Hi Dave and Fellow Radsafers,
>>
>>I think Dave is wrong on the above point.  In fact, a licensee may
>>transfer unlimited numbers of single exempt quantities to the same
>>(unlicnesed) person.  There is no limit on the number of single exempt
>>quantities a person may receive or accumulate. Implied in this is that a
>>person may not combine exempt quantities.
>>
>>See 10 CFR 30.18(a).
>>
>>Cheers, Wes
>>--
>>Wesley R. Van Pelt, Ph.D., CIH, CHP                   KF2LG
>>President, Van Pelt Assoc., Inc.      vanpeltw@mail.idt.net
>>Consulting in radiological health and safety.
>>"TIME, its what keeps everything from happening at once."
>>
>>
>
>
Unforunately when we conduct a houshold hazaroudous waste turn-in's under
EPA conctract.. we are not allowed to take smoke detectors...any number as
they are radioactive!!! The functional unit of the company is separate from
any that has RAML..  Our TSD part B facility cannot accept anything
radioactive...even obviously expempt quantities from a non-license holder to
a non-license holder..i.e. less than 0.05% zirconium blasting grit, lab
packs of uranium and thorium compounds even though the agreement state and
the NRC says the material is "not radioactive" for the purposes of disposal.

A customer recently had 500 cu-ft of blasting material that had been used to
remove lead paint from a tank project... The material was sold to them
exempt...less than 0.05% thorium or uranium.  The company's use of the
material added a RCRA hazard that they were familiar with... they had a RCRA
part B facility "on board" to take their blasting grit.  Unfortunately this
facility had also installed NaI detectors at their gates.  You can guess how
far the zirconium (niobioum--columbium) sands went.  The customer was left
to find a RCRA part B facility that did not have rad detection equipment or
go to Envirocare as Barnwell was not even possible with the RCRA
characterization.

There is a much larger problem with a variety of isotopes and
consumer/business products not usually thought of as radioactive.  Not only
do you have the smoke detectors with Am-241, you also have your lantern
mantles, sand blasting grits and others..

Will our govenment agencies ever agree on what is "radioactive".
Not in my lifetime...

Erik 8-}
If it isn't in writing, it didn't happen