Re[2]: NRC Licensing of Am-241

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

     Clearly, it becomes painfully obvious that the term "exempt from 
     licensing" is not the same as "exempt from all headaches"...
     
     Eric Darois
     daroiel@naesco.com


______________________________ Reply Separator _________________________________
Subject: Re: NRC Licensing of Am-241
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    10/28/96 10:15 PM


     
>>
>>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