Re: NRC Licensing of Am-241 -Reply -Reply

[Keith Brown <KDB1@nrc.gov>]

>>>>>>>>>>>>>>>
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.

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

<<<<<<<<<<<<<<<
No.  I used "exempt" precisely.  I should have said "detector", rather
than "gauge."  My point was there is not maximum for the quantity of RAM
in certain items distributed as exempt.  Several postings seemed to imply
that exempt items contain less than exempt quantities.  I do not believe
there is any limit on items distributed under 10 CFR 32.26.  The
manufacturer must show that the containment, shielding, or other safety
devices will no fail in use and disposal (32.27), which is the safety analysis
to which I referred (o.k., that terminology was sloppy).  Granted the
probability of my proposed device working or it being approved for exempt
distribution are nil.  But I picked a gedanke experiment to be outlandish to
make clear my point.

By the way, I think 32.22 (self-luminous products) also does not limit the
activity per device.

Once again, these are my opinions only, and now I will shut up.

Keith Brown
kdb1@nrc.gov