Re: License Issues for Radiochemistry

[Lester.Slaback@nist.gov]

I>example, actinide analysis of soil, splitting of urine, etc.).  Who owns
>the leftover sample matrix?  Who disposes of it?

That is between you and the person who sent it to you.  If you can arrange
to return all materials to the sender then they have the problem.

>Our laboratory performs very low level analyses.  We routinely quantify 
>actinides in matrices that have had no other actinide input other than 
>global fallout.  Does quantifying actinides in this matrix make any 
>remaining matrix Class A waste?  Is there a lower limit to Class A waste
>for actinides?   

We had a similar situation a few years ago.  NBS was analyzing soil and
certifying it for it's radionuclide content, including it's Pu content. 
No radioactive material was added in the process.  Does the material now
analyzed and certified become licensed material.
After about 3 years of discussion NRC issued a legal position that
determined that this process did not make this dirt subject to NRC rules,
and that we can in fact sell it as a standard with people having to get a
license to possess Pu.  There were some important caveats, e.g., no
separation or enrichment procedures, but this would seem to apply to your
situation.

The bad news is that was an opinion issued to NBS.  You would probably
have to go thru the same process.

-- 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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