Re: thoriated tungsten -Reply

["Kent N. Lambert" <lambert@auhs.edu>]

Part 40 exempts the use of welding rods from licensing. 
10CFR40.13(c)(1)

10CFR20.1001 Purpose
The regulations in this part establish standards for protection 
against radiation resulting from activities conducted under licenses 
issued by the NRC.

It is the purpose of the regulations in this part to control ... 
licensed material ...

10CFR20.1002 Scope
The regulations in this part apply to persons licensed by the 
Commission...

It seems pretty clear that Part 20 does not apply.

On 22 Dec 97 at 15:58, Kenneth Prendergast wrote:

> Without looking at Part 20, I think it depends on the extent the
> worker is documented in the license.  If the worker is listed as a
> user, than I think the portion of Part 20, that includes dose from
> unlicensed sources could be used to regulate the dose. However, if
> the worker is not listed on or tied to the license then this dose
> does not fall under Part 20.  '
> 
> KMP@ NRC.GOv.  These are my comments and not those of the agency>
Kent N. Lambert, M.S., CHP
lambert@auhs.edu
Allegheny University of the Health Sciences
Hahnemann Division
Radiation Physics and Safety, MS 106
Broad and Vine Streets
Philadelphia, PA  19102-1192

215-762-8768 (voice)
215-762-7683 (fax)  

Disclaimer:  All opinions are well reasoned and insightful.
Needless to say, they are not (necessarily) the opinions of my employer.