RE: NARM

[MARK WINSLOW <WINSLOW.MARK@epamail.epa.gov>]

We encountered a similar problem several
years ago with some NORM calibration
standards.

In NY and NJ NORM and NARM are regulated
by the state.  However, because we are a
federal facility we are not subject to state
regulation.  The next monkey wrench is an
executive order or the federal facilities
compliance act which states all federal facilities
must comply with state and local regulation.  So
now your back to being subject to local
regulation.

We ended up obtaining a letter of
understanding from New York state saying we
could keep these sources and a licences was
not required because of the low levels.

I would contact the Florida office of radiation
control at (904) 487-1004.  Also remember a
source is only exempt if the manufacture is
licenced to produce exempt sources.

Mark Winslow
winslow.mark@epamail.epa.gov