Re: Exempt vs. Non-licensed ?

[Michael Kay <mikekay@teleport.com>]

Eric L. Darois wrote:
> 
>      Be carefull what you ask for, you just may get it, and it could look
>      like this:
> 
>      "all radioactive material must be possessed and controlled with a
>      specific license"...
> 
>      Eric Darois
> 
> ______________________________ Reply Separator _________________________________
> Subject: Re: Exempt vs. Non-licensed ?
> Author:  radsafe@romulus.ehs.uiuc.edu at Internet
> Date:    10/29/96 8:59 AM
> 
> It seems to me that with all of the "convolutions" we have with respect to
> what is regulated and what is not, we should be focusing on a "Flat
> Regulation" fashioned after the "Flat Tax" concept. A regulation that
> is simple and can still be contained on a postcard!!!
> 
> Sandy Perle
> Director, Technical Operations
> ICN Dosimetry Division
> Office: (800) 548-5100 Ext. 2306
> Fax: (714) 668-3149
> 
> E-Mail: sandyfl@ix.netcom.com
One way to look at this question is that there is no such thing as an
exempt source for a licensee. I have been RSO for two colleges with 
broad licenses in Oregon. Basically, if you have a broad license, all
sources--even instrument check sources attached to the sides of the
cases of GM counters need to be on the list of sealed sources filed with
Oregon Radiation Protection Services. The reason is exactly to prevent
the situation where the sum of the quantities of exempt sources, each
exempt individually, exceeds the exempt limit in sum. I would assume
that this condition holds for all broad licensees. 

As a note, when you are in this license condition, it is all too easy to
misplace one of the sealed sources, especially the little disc check
sources, and that is the day the regulators come to inspect your
operation--and they want to verify the list of sealed sources. Once when
I was handling RSO duties for a person on sabbatical, it took me over a
week to track down every sealed source, and I only had two labs, a
counting room, and a neutron howitzer room to look in.

Michael Kay, ScD, CHMM
mikekay@teleport.com