Re[2]: Exempt vs. Non-licensed ?

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

     Michael;
     
     Your point represents one of the important inconsistencies that exist 
     accross the country regarding this topic.  I can certainly interpret 
     the regulations in the same way.  However, in my experience with many 
     broad scope licensees (Nuclear Power Plants and others), the practice 
     has been just the opposite for inventory and control of exempt 
     sources.
     
     Irrespective of the source control issue, I dissagree with the need to 
     combine source activities to determine the exempt or non-exempt 
     status.
     
     Eric Darois, CHP
     daroiel@naesco.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