Re: Beta source available

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

So, if a shipment of Pd-103 seeds are inadvertently shipped to me 
rather than UPenn, I could transfer them to UPenn, but UPenn could 
not use them on a patient.  For UPenn to use them as intended, I 
would have to ship them back to the manufacturer, and the 
manufacturer would would then ship them to UPenn.  How would UPenn 
know that I forwarded the shipment to them? 

My license says, " a license is hereby issued authorizing the 
licensee to receive, acquire, possess, and TRANSFER byproduct, source 
and special nuclear material designated below ... to persons 
authorized to receive it ..."

10 CFR 30.41 says " No licensee shall transfer byproduct material 
except ...to any person authorized to receive such byproduct material 
under the terms of a specific license..."  And it further states how 
one determines if a person is authorized.

Where it becomes interesting is in 30.32(g) which says, "An 
application for a specific license to use byproduct material in the 
form of a sealed source ... must either identify the source or device 
by manufacturer and model number as registered with the Commission 
under 32.310 ... or contain the information identified in 32.210(c)."

So, the point is not medical v. other purposes, unless I missed 
something in Part 35 (which is possible at 5:30 on a Friday 
evening) but whether it is an NRC recognized sealed source and, as 
always, whether the recipient is authorized for that specific 
material (in this case identified by manufacturer and model number).  

On  6 Feb 98 at 15:01, Kenneth Prendergast wrote:

> Although, my interpretation may not be favorable from your point
> of view, because the device is going to be used for medical
> purposes more stringent regulations appear to apply.  I am aware of
> a licensee in HI that acquired a number of sr-90 sources and they
> could only be used for calibration.  They could not be used for
> medical purposes.

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.