Re: NRC Licensing of Am-241 -Reply

[Lynn McGuire <elmcguire@LIFE.UAMS.EDU>]

In the interest of clarity (I hope), my comments re: "exempt
distribution" remarks of Keith Brown are listed  -please correct me
if I'm wrong.  I think his use of EXEMPT was at least imprecise; the
case he uses as an example (1 Ci Cs-137),as do most GL's, carry
significant requirements most persons are not aware of  until they
try to track down lost/destroyed devices; for example, LSC's
containing sources.

1. Part 32 contains provisions for distribution of EXEMPT QUANTITIES
of materials; no safety analysis per se is required, i.e. a public
health dose assessment. (10CFR32.19).

2. Part 32 also contains a section for distribution of GL's, which
have NO UPPER ACTIVITY. There are, however, strict criteria for
distribution of these devices with regard to doses to public; see
32.51(a)(iii)- ordinary doses to public must be <10% MPD as well as
the catastrophic accidents and containment integrity issue (32.51(a)
(ii) which are, BTW, 15 rem whole body and 50 rem organ.

------------------------------------------------------------------------------
Date:          Mon, 28 Oct 1996 08:52:46 -0600
From:          Keith Brown <KDB1@nrc.gov>
Subject:       Re: NRC Licensing of Am-241 -Reply
To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Reply-to:      radsafe@romulus.ehs.uiuc.edu


As a somewhat off-subject note: devices that can be distributed under an
exempt distribution (specific) license may contain more that an exempt
quantity of material.  If one produced a gauge that contained a curie of
cesium-137, and if it could be shown that there was essentially no external
radiation and that the containment could not be breached, etc. by
tampering or otherwise for about a thousand years (30 half lives to let the
curie decay), it might be approved for exempt distribution.  (Obviously, this
scenario is unrealistic.)  In other words, for manufacturers who go through
safety analysis of products, it the safety analysis rather than the quantity
that determines ability to distribute as exempt.

Again, all the above are my opinions.  They may be worthwhile, or you
may get what you paid for.

Keith Brown
kdb1@nrc.gov
-------------------------------------------------------------------------

Lynn McGuire - ELMCGUIRE@LIFE.UAMS.EDU
Veterans Health Administration (VHA) 
Little Rock AR 
DISCLAIMER: Not speaking in any official capacity of VHA