Re: exempt quantities

["Betty E Schwab" <bschwab@hsc.vcu.edu>]

Radsafers,
    Thanks for your replies to my question about how NRC licensees
should treat exempt quantities.  The answer seems to be that certain
specific products may be exempted from Part 20 requirements, but exempt
quantities of RAM under Part 30 are not exempted from Part 20
requirements.  Obviously, products such as watches, gas detectors,
tritium exit signs at our facilities are exempt from Part 20 or else we
would have to regulate these products as RAM under our licenses.

    The C-14 urea capsules for detection of H. pylori are expected to
become exempt under Part 30, but NOT from Part 20 requirements.  As one
of the NRC subscribers who replied to my post pointed out, this
difference is only important to those who are licensees.  Licensees that
receive the C-14 urea capsules will have to meet Part 20 requirements.

    A general license is different from exempt quantities.  As I
understand the regulations, a medical licensee can also have an RIA in
vitro clinical lab (for example) that operates under a general license
as long as the requirements under Part 31 are met.  This would free the
clinical lab from lots of paperwork and disposal requirements.

Betty Schwab, MPH
Radiation Safety Supervisor
Virginia Commonwealth University
Richmond, VA