RE: Exempt Quantities

["David W. Lee" <lee_david_w@lanl.gov>]

	I think Jim Herrold's comments correctly interpret 10 CFR 30.18, with the
caveat that I am not employed by the NRC nor an NRC-licensing expert.
Perhaps one or more NRC employees on the RADSAFE net can comment.  Betty
Schwab stated that her university has a byproduct material license from the
NRC, not a BML from an Agreement State.  Then is it also correct to
interpret or recognize that her university could have radium (NRC does not
regulate it); or Co-57 (accelerator-produced; not regulated by the NRC),
neither of which is therefore listed in 30.71, and these radioactive
materials would not fall under NRC license jurisdiction.  Hence, these
materials could be treated as being outside of NRC regulations and would
not necessarily have to be inventoried/accounted for and lumped together
with NRC-regulated radionuclides???

REGARDS  David




At 01:41 PM 04-11-97 -0600, you wrote:
>Betty:
>
>This is the way we understand this regulation: The exemption in 10 CFR
>30.18 exempts people from LICENSING requirements for total quantities of
>radionuclides not exceeding 30.71 Schedule B. If you already have a
>broad-scope license you obviously are not exempt, so any quantity of
>radioactive material you receive is covered under your license. At the
>University of Wyoming, all radionuclides received must be approved and
>processed through the Radiation Safety Office, whether or not they are
>below the 30.71 Schedule B quantities. All waste is picked up and
>disposed the same way. The University is the licensee, not the
>researcher. It should be the same at your institution, unless otherwise
>allowed under your license.
>
>Jim F. Herrold
>Radiation Safety Officer
>University of Wyoming
>Environmental Health & Safety
>312 Merica Hall
>Laramie, WY 82071
>
>herrold@uwyo.edu
>(307) 766-3277
>
>>----------
>>From: 	Betty E Schwab[SMTP:bschwab@hsc.vcu.edu]
>>Sent: 	Tuesday, November 04, 1997 9:13 AM
>>To: 	Multiple recipients of list
>>Subject: 	Exempt Quantities
>>
>>    At Virginia Commonwealth University we have a medical center and a
>>research community.  We would like to know how other universities or
>>institutions with broad byproduct materials licenses from the NRC treat
>>exempt quantities of RAM that do not require a license to order. Do you
>>operate as if there are no exempt quantities under your license?  Or, do
>>
>>you allow users to order, receive and dispose of exempt quantities
>>without regard to your license.
>>    An example is the C-14 PYTest for H. pylori, which will not require
>>an NRC license if the proposed NRC ruling is approved.  Would you allow
>>a user in your institution to order, use and dispose of the radioactive
>>material waste in the regular trash?  Or would they have to meet all
>>license requirements as required of users of larger quantities?
>>
>>Betty Schwab, Radiation Safety Supervisor
>>bschwab@hsc.vcu.edu
>>
>>
>>
>>
>
>
David W. Lee
Los Alamos National Laboratory
Radiation Protection Services Group (ESH-12)
PO Box 1663, MS K483
Los Alamos, NM  87545
PH:   (505) 667-8085
FAX:  (505) 667-9726
lee_david_w@lanl.gov